Privacy Policy
Last updated: November 6, 2026
Dev-H | Trk-H
1. Introduction
At Dev-H, we believe privacy should be an integral part of how technology works.
Trk-H is designed to perform all head tracking calculations directly on the device, without requiring cloud-based tracking services or continuous internet connectivity.
This Privacy Policy explains how Dev-H collects, uses, stores, and protects personal information when you visit our website, purchase Trk-H products, register your device, use the Trk-H Control Center (CC), or contact customer support.
We process personal information in accordance with the European Union General Data Protection Regulation (GDPR) and applicable Finnish data protection legislation.
2. Data Controller
The data controller responsible for your personal information is:
Dev-H
Business ID: 3658039-3
Pitäjäntie 3
07170 Pornainen
Finland
Website: https://www.trk-h.com
For privacy-related inquiries and personal data requests, please use the contact form available on our website.
3. What Information We Collect
The information we process depends on how you interact with our services.
3.1 Online Store and Orders
When you purchase a product through our online store, we may process:
- Your name and contact information
- Billing and shipping addresses
- Email address and telephone number, where provided
- Order details, purchased products, and transaction history
- Payment status and transaction references
- Shipping and delivery information
- Information necessary for returns, refunds, and warranty claims
Our online store is provided through Ecwid by Lightspeed.
3.2 Payment Processing
Payments in our online store are processed through Stripe and PayPal.
Depending on your selected payment method, the relevant provider processes information necessary to complete transactions, prevent fraud, and comply with applicable financial regulations.
Dev-H receives payment confirmations, transaction references, and information necessary for order management, refunds, and accounting.
For further information, please refer to the providers' privacy policies:
- Stripe: https://stripe.com/privacy
- PayPal: https://www.paypal.com/privacy
3.3 Trk-H Device Identification
Each Trk-H device has a unique identification mechanism used for device authentication, security, firmware management, and related services.
Our systems may process technical information such as:
- Unique device identifiers
- Firmware and software versions
- Device activation and registration status
- Device authentication and security status
- Relevant firmware update and service request information
A device identifier may be considered personal data when associated with an identifiable individual.
Device identification is separate from optional personal registration.
3.4 Optional Device Registration
Device registration is available through the Trk-H Control Center (CC).
Registration is entirely optional and is not required for normal head tracking operation.
If you choose to register your device, we process the contact information you provide and associate it with your device identifier.
Registration enables faster and more efficient customer support by allowing us to identify your device and access relevant technical information.
Registration is based on your voluntary consent, which you may withdraw by unregistering your device.
3.5 Customer Support
When you contact customer support, we may process:
- Your name and contact details
- Your device identifier, where available
- Support tickets and correspondence
- Technical information you provide
- Troubleshooting information relevant to your request
When a support ticket is submitted through the Trk-H Control Center, a snapshot of the device's current configuration is included to help diagnose technical issues.
This snapshot contains device settings and configuration parameters. It does not include recorded head movements or special-category personal information.
The configuration snapshot is stored together with the support request and is used for troubleshooting, customer assistance, and identifying recurring technical issues.
Registered customers can submit support tickets directly through the Control Center.
Customers who prefer not to register can access alternative support contact information through the Control Center.
3.6 Website and Technical Information
When you visit our website or use our online services, certain technical information may be processed by our hosting and service providers.
Depending on the service and configuration, this may include IP addresses, browser information, request timestamps, security events, and cookies or similar technologies.
Such information is processed where necessary to operate, secure, and maintain our online services.
Dev-H does not routinely collect or retain device operation logs or head tracking movement history.
4. How We Use Your Information and Our Legal Bases
We process personal information only when we have an appropriate legal basis.
| Purpose | Legal basis |
|---|---|
| Processing purchases, payments, deliveries, returns, and contractual support | Performance of a contract |
| Maintaining accounting, tax records, and complying with statutory obligations | Legal obligation |
| Optional device registration and associated registration features | Consent |
| Device authentication, fraud prevention, and service security | Legitimate interests |
| Customer support and troubleshooting | Performance of a contract or legitimate interests, depending on the request |
| Improving product reliability and support quality | Legitimate interests, subject to necessity and balancing |
| Optional marketing communications | Consent, where required |
| Essential website and shopping cart functionality | Contractual necessity or legitimate interests, as applicable |
| Optional analytics and non-essential cookies | Consent, where required |
Where processing is based on legitimate interests, we consider the necessity of the processing and its potential impact on individuals.
You may withdraw consent at any time where consent is the legal basis for processing.
5. Head Tracking Data and Offline Operation
Your head movement data is processed locally by Trk-H.
The device performs sensor fusion, filtering, prediction, and motion modeling on its own hardware.
The finished tracking data is delivered locally to your computer and supported games.
Normal head tracking operation does not require uploading your head movement data to Dev-H servers.
Trk-H does not require continuous internet connectivity for normal tracking operation.
An internet connection may be required for firmware updates, device authentication checks, online configuration services, and customer support functions.
6. Device Registration and Unregister
Trk-H registration is designed to give you control over the personal information associated with your device.
You can register your device directly through the Trk-H Control Center.
If you wish to update your registration details, you can unregister the device and register it again using the corrected information.
Selecting Unregister automatically removes the personal registration information associated with your device from the active registration database.
Unregistering does not prevent you from using Trk-H for normal head tracking.
Unregistering does not automatically delete unrelated purchase records, legally required accounting information, or support correspondence retained for a separate lawful purpose.
Personal information previously included in database backups may remain until those backups expire under the retention schedule described below.
You may also contact us to exercise your data protection rights regarding information held in other systems.
7. Data Sharing and Service Providers
We do not sell your personal information.
We share or make information available only where necessary to operate our services, fulfill purchases, provide support, maintain security, or comply with legal obligations.
Depending on the service, recipients may include:
- Ecwid by Lightspeed: Online store operations and order management
- Stripe: Payment processing and transaction security
- PayPal: Payment processing and transaction security
- Shipping and delivery providers: Order delivery and shipment management
- Cloudflare: Website hosting, online infrastructure, and relevant device services
- Email service providers: Customer support correspondence and related communications
- Public authorities: When disclosure is required by applicable law
Other service providers may be used where necessary for the operation of our services.
Service providers process personal information according to their respective responsibilities and applicable data protection obligations.
8. International Data Transfers
Dev-H operates from Finland, within the European Union.
We use third-party service providers, including Ecwid by Lightspeed, Cloudflare, Stripe, PayPal, and delivery providers, to operate our online store and related services.
Some of these providers may process or access personal information outside the European Economic Area (EEA).
Where international transfers are subject to GDPR transfer requirements, we rely on applicable safeguards, such as European Commission adequacy decisions or Standard Contractual Clauses, as appropriate.
For further information about international data transfers and applicable safeguards, please contact us through our website.
9. Data Retention
We retain personal information only for as long as necessary to provide our services, fulfill legal obligations, maintain service quality, and resolve technical or customer-related issues.
Our retention practices distinguish between different categories of information:
- Purchase and accounting records: Retained for the periods required under Finnish accounting and tax legislation.
- Optional device registration: Registration information is retained while the device remains registered. Using the Unregister function removes the associated personal registration information from the active database.
- Support tickets and correspondence: Customer support communications are retained for up to 24 months after the support case is closed, after which they are automatically deleted according to our email retention policy. Records may be retained longer where necessary to comply with legal obligations or to establish, exercise, or defend legal claims.
- Device configuration snapshots: When a support ticket is submitted through the Trk-H Control Center, a snapshot of the device's technical configuration is included to assist with troubleshooting. These snapshots contain no recorded head movement history or special-category personal information and are retained as part of the corresponding support ticket.
- Technical logging: Dev-H does not routinely collect or retain device operation logs or head tracking movement history. Limited technical information may be processed by infrastructure providers as necessary to operate and secure online services.
- Marketing information: Retained until consent is withdrawn or the information is no longer necessary for its intended purpose, subject to applicable legal requirements.
- Database backups: Database backups are retained for up to 12 months for disaster recovery and data integrity purposes, after which they are removed according to the backup retention schedule.
Device registration recovery: In the event of a database restoration, previous customer registrations are not restored. Customers must register their devices again through the Trk-H Control Center. This prevents previously deleted registration information from being reintroduced into the active customer database.
Personal information deleted from active systems may remain in protected backups until those backups expire, but it will not be restored as active customer registration data.
Personal data may also be deleted earlier where required by applicable data protection laws.
10. Cookies and Similar Technologies
Our website and online store use cookies and similar technologies to provide essential functionality, maintain security, and remember user preferences.
These may include:
- Essential cookies: Required for shopping cart functionality, checkout, session management, and other core services.
- Security cookies: Used by our infrastructure providers, including Cloudflare, to help protect against malicious traffic and automated abuse.
- Preference cookies: Used to remember user preferences and applicable consent choices.
- Analytics and marketing cookies: Used where enabled and subject to applicable consent requirements.
Non-essential cookies are used only when the required consent has been obtained.
Visitors can manage applicable cookie preferences through the consent controls provided on our website or online store.
For additional information about the cookies used by our service providers, please refer to their published privacy and cookie documentation.
11. How We Protect Your Information
We take appropriate technical and organizational measures to protect personal information against unauthorized access, loss, alteration, and disclosure.
These measures include, where applicable:
- Secure connections for online services
- Device-specific identification and authentication
- Access controls for administrative systems
- Security measures designed to protect firmware and device services
- Restricted access to customer information
- Appropriate security practices for service providers
Although no electronic system can guarantee absolute security, we aim to minimize the personal information we collect and limit access to what is necessary.
12. Your Data Protection Rights
Under the GDPR, you may have the right to:
- Access personal information we hold about you
- Request correction of inaccurate information
- Request deletion of personal information
- Request restriction of certain processing activities
- Object to processing based on legitimate interests
- Receive certain information in a portable format
- Withdraw consent where consent is the legal basis
- Lodge a complaint with a data protection authority
These rights apply subject to the conditions and limitations established by law.
You can remove your optional Trk-H registration directly through the Control Center using the Unregister function.
For requests concerning purchase records, customer support information, or other personal data, please use the privacy contact form available on our website.
We may need to verify your identity before responding to certain requests.
You also have the right to lodge a complaint with the Finnish Data Protection Ombudsman:
13. Information Required to Provide Our Services
Certain information, such as delivery details and necessary transaction information, is required to fulfill an online purchase.
If this information is not provided, we may be unable to process or deliver your order.
Optional device registration information is not required to operate Trk-H.
You can use Trk-H without registering personal contact information.
14. Automated Decision-Making
Trk-H uses automated technical processes for device identification, authentication, firmware management, and service security.
These processes are not intended to profile customers or make decisions based on their personal characteristics.
Dev-H does not use customer personal information for solely automated decision-making that produces legal or similarly significant effects within the meaning of Article 22 of the GDPR.
15. Changes to This Privacy Policy
We may update this Privacy Policy to reflect changes in our services, technology, or legal obligations.
The latest version will be made available through our website, and the date at the top of this document will indicate when it was last updated.
Where required by law, we will provide additional notice of significant changes.
16. Contact
For questions about this Privacy Policy or requests concerning your personal information, please use the contact form available on our website.
Dev-H
Business ID: 3658039-3
Pitäjäntie 3
07170 Pornainen
Finland
Website: https://www.trk-h.com
Device registration can also be managed directly through the Trk-H Control Center.