Privacy policy

Updated: 24 August 2019

In this Privacy Policy, “XLABS” or “We” or “Us” or “our” refers to all websites (including but not limited to, and all associated sub-domains and domains) along with products and services owned or operated XLABS Pty Ltd ACN 167 607 927 and its subsidiaries.

This Privacy Policy explains how and when XLABS collects end user and client information, which may include information that personally identifies you (“Personally Identifiable Information”), how we use such information, and the circumstances under which we may disclose such information to others.

By visiting the XLABS Websites; by registering for, downloading and using XLABS Client Software, you acknowledge that you accept and consent to the practices outlined in this Privacy Policy.

We respect information privacy. We do not collect sensitive information such as racial or ethnicity information, political opinions or health information.

Please note this Privacy Policy does not cover the practices of any third parties or their services, including XLABS Approved Clients who may use XLABS services. For information about third party privacy practices, please consult their privacy policies.

Information we collect and how we use it

Visitors to the XLABS Websites

Information we collect automatically

When you use our Websites, XLABS may collect non personal information provided by your browser or mobile device, such as your computer’s operating system, browser information, Internet Protocol (IP) address, mobile device information, access times, browser type and language, time of last visit, previous site visited. We may also collect information about your usage and activity on our Websites via measurement and tracking technologies such as Google Analytics. If you do not register as a user on our website, no Personally Identifiable Information will be collected.

Information you provide to us

When you register to use our product via the XLABS websites (including for the purposes of registering as a user or developer of the XLABS software, or to post to our forum), we will collect various types of information about you. This information you provide may include Personally Identifiable Information that you explicitly and voluntarily give us including for example, your name, company name, email address, phone number, website URL, address. (“XLABS User Information”).

How we collect your personal information on our website

XLABS may collect personal information about you in a variety of ways from our website including, but not limited to:

  • When you register to download our software products, as an end user, as governed by our EULA

  • Subscribing to receive our newsletter, or choosing to participate in surveys, promotions or competitions

  • Contacting us via online forms for various reasons including feedback, technical support, and employment opportunities or seeking more information

  • Joining and posting onto our forum or commenting on our blog

  • We use XLABS User Information, including any Personally Identifiable Information you provide, to register your account, fulfill your requests, provide and deliver our products and services that you use such as the XLABS Client Software, understand how you are engaging with XLABS, communicate with you, and to provide you access to the forum

Use of XLABS Client Software

XLABS Client Software, which runs on your personal computer, includes a range of features that can be operated and controlled by you. Registration and agreement to the End User License Agreement is required in order to download and use XLABS Client Software.

General use

Activation of the XLABS Client Software is only possible when initiated or accepted by you, the user, via our interface. Each time the XLABS Client Software is activated, the associated email address used during the XLABS Client Software registration, and the IP address of the user’s computer running the XLABS Client Software, and time of use, are transmitted and recorded by XLABS (“Usage Message”).

All video and image processing occurs within the XLABS Client Software running on your computer. No camera images or video are EVER transmitted by the XLABS Client Software to any other computer. Futhermore, the XLABS Client Software blocks any request to stream video or images to other computers.

Use of XLABS Client Software during web browsing, when activated by the user

When activated by the user, XLABS does not collect any information about use of the XLABS Client software except the Usage Message outlined in the General Use section above.

Activation of XLABS Client Software by third party websites

The XLABS Client Software can only be activated by third party websites with consent from the user. When a website requests activation of the Client Software, the user is shown a dialog asking them to consent. If the user does not consent, the website is unable to activate any features of the Client Software and cannot access any user data.

When the user accepts a request from a website to enable the XLABS Client Software, a message is transmitted to XLABS containing the URL of the website being visited, and the time. The IP address of the user’s computer that sends this message is not collected by XLABS.

Data made available to third party websites, with consent

If the user consents, data collected by the XLABS Client Software is made available to third party websites. XLABS cannot and does not control the use of that data by third parties. This data includes:

  • The username used to operate the XLABS Client Software

  • A stream of data representing the head and eye pose of the user

  • A stream of data representing the gaze coordinates of the user

  • The configuration of the XLABS Client Software

Use of Cookies

XLABS may use first party cookies (small text files that the XLABS website stores locally on your computer) on our websites, for one or more of the following purposes: to help identify unique and returning visitors and/or devices; conduct A/B testing; and diagnose problems with our servers. Browsers do not share first-party cookies across domains. XLABS does not use methods such as browser cache, Flash cookies, or eTags, for acquiring or storing information about end users’ web browsing activity.

You can set your browser preferences to refuse all cookies should you wish to prevent cookies from being used.

Disclosure of Information to Third Parties

We do not share your personal information with third parties other than as follows.

Service Providers

Information, including XLABS User Information, and any Personally Identifiable Information contained therein, may be shared with certain third-party companies and individuals that help facilitate technical and administrative aspects of the XLABS Service (e.g. email communications), or perform functions related to the administration of XLABS (e.g. hosting services). These third parties perform tasks on our behalf and are contractually obligated not to disclose or use XLABS User Information for any other purpose, and to employ adequate security measures to prevent unauthorized access to such data. However, XLABS is not responsible in the event that Personally Identifiable Information is disclosed at a result of a breach or security lapse by any such third party.

Law Enforcement and Legal Process

XLABS also reserves the right to disclose any Client User Information (including Personally Identifiable Information) to: (i) comply with laws or to respond to lawful requests and legal process, judicial proceeding, or court order (ii) to protect the rights and property of XLABS, our agents, clients and others including to enforce our agreements, policies and terms of use or (iii) in an emergency to protect the personal safety of XLABS, its Clients, or any person.

Business Sale

If XLABS, or substantially all of its assets, is acquired by another company or successor entity, XLABS Client Information will be one of the assets transferred or acquired by the purchaser or successor. You acknowledge that such transfers may occur, and that any purchaser of or successor to XLABS or its assets may continue to collect, use and disclose your information acquired prior to such transfer or acquisition as set forth in this policy.

Security of your Personal Information

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. Examples of these include limited and password-protected access, high security public/private keys and SSL encryption to protect transmission. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

Provisions Specific to EU Citizens

Rights of EU Citizens Under the GDPR

If you are a citizen of the European Union you have certain rights relating to how others handle your personal information. These rights are:

1. The right to be informed how your personal information is being used.
2. The right of access your personal information and how it is processed.
3. The right to rectify inaccurate or incomplete personal information.
4. The right to deletion of all or any personal data.
5. The right to restrict processing, that is, the right to block or suppress processing of your personal data.
6. The right to data portability – this allows individuals to retain and reuse their personal data for their own purpose.
7. The right to object, in certain circumstances, to use of your personal data in a manner different from the purpose for which it was provided.
8. Right to prevent automated decision making or profiling based on your data without human intervention.


Changes to this Privacy Policy

XLABS reserves the right to amend or modify this Privacy Policy from time to time. If we make material changes to the way we collect, use or disclose Personally Identifying Information, we will notify you by posting a clear and prominent announcement on XLABS websites or through a direct communication to your XLABS account.

Use and disclosure of information we obtain is subject to the later of: (1) the Privacy Policy in effect at the time such information is collected or (2) any subsequent Privacy Policy of which you have constructive notice. Your continued access to or use of XLABS following constructive notice of material changes to this Privacy Policy shall constitute consent to any amendments and/or modifications.

Questions or Comments

If you have questions or comments about this Privacy Policy, please contact us by email at