Dunwoody Immersive Privacy Policy

Privacy Policy for Dunwoody Immersive VR Applications

Effective Date: 06/09/2026
Entity: Dunwoody College of Technology

1. Overview

Dunwoody College of Technology (“Dunwoody,” “we,” “our,” or “us”) provides virtual reality (“VR”) applications (the “VR Applications”), updated from time to time, as part of immersive educational programs delivered in collaboration with participating K-12 school districts to high school students who enroll in Dunwoody program courses.

The VR Applications are designed exclusively for use in structured educational environments and are accessed by participating students enrolled in Dunwoody courses.

This Privacy Policy describes how information is collected, used, and protected when student users interact with Dunwoody’s VR Applications distributed through the Meta Horizon platform.

By accessing and using the VR Applications, each user consents to Dunwoody’s use of their data consistent with the terms of this Privacy Policy.

2. Educational Context

Dunwoody provides the VR Applications as part of official academic coursework.

• Use of the VR Applications occurs in accordance with agreements that have been executed with participating K-12 school districts and/or schools within such districts.
• In providing the VR Applications and collecting or using data by users of the VR Applications, Dunwoody operates as a school official with legitimate educational interest in a student’s education records under the Family Educational Rights and Privacy Act (FERPA)
• The VR Applications are not intended for general consumer use
• Participating K-12 school districts and schools are required, pursuant to their participation agreement with Dunwoody, to have each participating student user of the VR Applications and, in the case of a minor Student user, their parent or legal guardian, sign a written FERPA authorization forms to consent to the collection and sharing of data about the student by and between Dunwoody and the Student user’s school district and school.

3. Information We Collect

Dunwoody’s VR Applications are intentionally designed to seek to minimize the volume of data collected through the applications and to seek to avoid collecting personally identifiable information (PII) within the VR learning environment.

Dunwoody may collect the following categories of information through the VR Applications:

a. Application Usage Data

• Time spent by a user in VR experiences
• A user’s Lab/module completion status
• Interaction events by the user within the VR Application

b. Performance and Progress Data

• A user’s completion of learning objectives
• A user’s task results and progress events

c. Device and Technical Data

• A device identifier (provided by the platform) used only at the time of session authentication
• VR Application performance and diagnostic data

d. Crash and Error Data

• Crash reports and system diagnostics provided by the Meta platform

4. What We Do NOT Collect

The VR Applications do not collect:

• Names
• Email addresses
• Student IDs
• Biometric data (e.g., eye tracking, facial recognition)
• Audio recordings
• Video recordings
• Precise location data
• In-app communications or messaging

User identity is managed outside of the VR Applications through secure session-based authentication systems.

5. Authentication and Identity

Access to the VR Applications is enabled through a secure session process:

• Users obtain a one-time session code through a Dunwoody or their high school-managed learning system (e.g., Canvas)
• The VR Applications exchange this code for a temporary session token
• The VP Applications do not store or process user identity

All identity attribution occurs outside of the VR Applications in Dunwoody’s secure backend systems.

6. How We Use Information

We use collected data from the VR Applications solely for educational and operational purposes, including:

• Delivering and operating VR learning experiences
• Tracking participating student progress and completion of course requirements
• Supporting academic assessment of students and reporting on the same
• Maintaining system functionality and reliability
• Improving instructional design and learning outcomes

We do not use the data for:

• Advertising
• Commercial profiling
• Sale of user data
• De-identified and aggregated data may be used for:
• Program evaluation
• Institutional reporting
• Research and continuous improvement

7. Data Sharing

Dunwoody does not sell or share personal data except as follows.

We may share data:

• With participating schools and school districts:
  For student progress reporting and academic purposes
• With an individual student user, limited to that individual’s data
• In de-identified, aggregated form:
  For reporting, research, or program evaluation

Dunwoody’s VR development vendors do not have access to user data.

8. Data Storage and Retention

Data is stored in secure infrastructure hosted in the United States (AWS).

Retention practices include:

Session data: short-lived (typically up to one hour)

Progress and performance data: retained as part of academic records

System logs: retained for a limited period (e.g., 90 days)

Data is retained only as long as necessary to:

Support educational outcomes

Support operational needs

Meet institutional and legal obligations

9. Security

Dunwoody implements commercially reasonable safeguards, including:

Encryption of data in transit and at rest

Secure authentication and session management

Access controls limiting data access to authorized personnel

Monitoring for unauthorized access or misuse

10. Third-Party Platforms (Meta)

These VR Applications are distributed through the Meta Horizon platform.

Meta may independently collect information according to its own privacy policies. Dunwoody is not responsible for and does not control Meta’s data collection practices.

Users should review Meta’s privacy policy for additional details.

11. User Rights and Requests

Because the VR Applications are used in an educational context:

Participating students and their parents/legal guardians should direct data access, correction, or deletion requests to the student’s high school or K-12 district

Dunwoody may coordinate with participating districts and schools to fulfill such requests

12. Children’s Privacy

The VR Application are not intended for children under 13.

The VR Applciations may only be used by high school students participating in Dunwoody immersive learning programs offered in collaboration with students’ K-12 district and/or high school.

13. Changes to This Policy

Dunwoody may update this Privacy Policy from time to time. Updates will be posted on the Dunwoody website with a revised effective date.

14. Contact Information

For questions about this Privacy Policy or data practices:

Email: immersive@dunwoody.edu