Privacy Policy

Version 1.0

Last updated: April 01, 2024

We respect your privacy and appreciate the trust you place in us when sharing your personal data. This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use the Service and tells you about your privacy rights and how the law protects you.

This Privacy Policy applies to the mobile application LEEM (the “Application” or the “Service”).

We use your personal data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

Who we are

Operating in Europe, STRUQT BV is a tech company focused on applying cutting-edge tech, scientific and artistic methods to the domains of synthetic realities (AR, VR, XR), spatial computing, and emerging media.

We act as the data controller, meaning that we determine what data is collected, how this data is going to be used and how this data is protected.

STRUQT BV is headquartered in the Netherlands and registered in the Dutch Chamber of Commerce under the number 83307419.

Our registered office address is:

Boschstraat 21A
6211 AS Maastricht

If you have questions about how we process personal data or would like to exercise your data subject rights, please email us at

What data do we collect and how do we use your data?

Below you will find an overview of the legal basis and purposes for the processing of your personal data. You will also find which data we use for that specific purpose and how long we keep this data.

Legal basis: Necessary for the performance of a contract
Purpose Data Type Retention period
Providing the service itself Email, User ID, Data necessary to provide the service, Data generated by the service As long as necessary for this purpose
Submitting reviews and/or messages Name, Email, Message/review content As long as necessary for this purpose
Handling inquiries and complaints about the product, Customer support Full name, Email, Phone number, Complaints/inquiries content As long as necessary for this purpose
Handling inquiries and complaints about the service, Customer support Full name, Email, Phone number, Data necessary to provide the service, Data generated by the service, Complaints/inquiries content As long as necessary for this purpose


Legal basis: Consent
Purpose Data Type Retention period
Direct marketing Full name, Email, Interest in a product As long as necessary for this purpose
Affiliate marketing Full name, Email, Interest in a product, Social media accounts As long as necessary for this purpose
Social media marketing Name, Email, Interest in a product, Social media accounts As long as necessary for this purpose

Use of personal data

We may use your personal data for the following purposes:

To provide, deliver, maintain and improve our products and services.

For the performance of a contract and to manage our business: the development, compliance and undertaking of the purchase contract for the products, items, or services you have purchased or of any other contract with us through the Service.

To contact you: To contact you by email or other equivalent forms of electronic communication, regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.

To provide you with news, special offers and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

To manage your requests: To attend and manage your requests to us.

For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Us about our Service users is among the assets transferred.

For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our services, products, marketing, and your experience.

How do we collect your personal data?

You directly provide us with the most data we collect. We collect and process data when you:

  • place an order for our Application,
  • voluntarily complete a survey or provide feedback via email or using one of our contact forms,
  • send us an email or message or make a phone call with a complaint, support request, or inquiry about any of our services or products,
  • fill in your data in our contact forms.

Indirectly by collecting usage data when you use our Application or when you use specific features of our Service.

Usage data may include information such as your device’s Internet Protocol address (e.g. IP address), browser type and version, the pages of the website that you visit, the time and date of your visit, the time spent on those pages, and other diagnostic data.

When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser you use, and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Website or when you access the Service by or through a mobile device.

Tracking technologies and cookies

We use cookies and similar tracking technologies to track the activity on our Website and store certain information. The technologies we use:

  • Cookies or browser cookies A cookie is a small file placed on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. If you refuse cookies, some of our Website features may not function as a result. Unless you have adjusted your browser setting so that it will refuse cookies, our Service may use cookies.

Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.

We use both session and persistent cookies for the purposes set out below:

Necessary / Essential cookies

Type: Session cookies
Administered by: Us
Purpose: These cookies are essential to provide you with services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Cookies Policy / Notice acceptance cookies

Type: Persistent cookies
Administered by: Us
Purpose: These cookies identify if users have accepted the use of cookies on the Website.

Functionality cookies

Type: Persistent cookies
Administered by: Us
Purpose: These cookies allow us to remember choices you make when you use the Website, such as remembering your login details or language preference. The purpose of these cookies is to provide You with a more personal experience and to avoid you having to re-enter your preferences every time you use the Website.

For more information about the cookies we use and your choice, please read our Cookie Policy.

Device permissions when using Application

We use this information to provide features, improve, and customize our Service. Depending on your specific device, when using some of the features of the Leem Application, the Application may request certain permissions that allow it to access data on your device.

When you want to use these features, you will be asked to grant permission. You solely control these permissions and you can enable or disable access to this information through your device settings at any time.

The exact procedure for controlling Application permissions may be dependent on your device and software. Please, keep in mind that when you revoke permission you will not be able to use some of the functionalities of the Application.

If you grant any of the permissions listed below, the respective personal data may be processed (i.e accessed to, modified or removed) by this Application or Service.

  1. Precise location permission

We use your location to provide location-based services.

You will be asked to give permission to use your location for:

  • the Application to notify you if there is digital or AR content in your proximity while you are not using the Application or
  • the Application to check, recommend and show you digital or AR content in your proximity while using the Application’s location-based features.
  1. Camera permissions

Used for accessing the camera to show AR content or to capture images and videos.

For example, when you use the Application and want to take a photo or a video you will be asked for permission to use the camera on your device.

  1. Photo library permissions

You will be asked to allow access to the photo library on your device if you want to save photos or videos you make while using the Application. If you allow permission this content will be stored in your device`s photo library.

Special and/or sensitive personal data

We do not collect sensitive data. Our Website and/or Service do not intend to and do not knowingly collect data about persons who are younger than 18 years of age. We, therefore, advise parents to be involved in the online activities of their children to prevent data about children from being collected without parental consent. If you are convinced that we have collected personal information about a minor, please contact us via and we will delete this information.

We may share your personal information in the following situations:

  • For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. In that case, we will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy.
  • With Affiliates: We may share Your information with our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  • With business partners: We may share your information with our business partners to offer you certain products, services or promotions that might interest you.
  • With other users: When using the Application, if you share personal information and content or otherwise interact in public areas with other users, such information and content may be viewed by all users and may be publicly distributed outside.
  • With your consent: We may disclose your personal information for any other purpose with your consent.
  • With Service Providers/Data Processors: We may share your personal data with companies that process data as a service to us. These parties are Data Processors within the meaning of the GDPR.
  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of users of the Service or the public
  • Protect against legal liability

Retention of your personal data

The Company will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), fully perform the contract with you, fulfil our legitimate purpose, resolve disputes, and enforce our legal agreements and policies.

Struqt will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for a longer period.

Transfer of your personal data

Your information, including personal data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Europe where the data protection laws may be different and not offer an adequate level of protection.

With companies that process personal data on our behalf outside Europe, we conclude contractual arrangements using the standard contractual clauses approved by the European Commission ensuring appropriate data protection safeguards for data transfers to third countries.

We have listed processing parties and explained what data is processed, why and where. We take care to keep this list up to date, however, if you find any inconsistencies please let us know via

  • Providing location-based services

Google Maps
Personal data: IP address, device and browser information, operating system, the content of the request, the date and time of the request, limited usage data, and limited location data.
When a mobile application uses Google Maps, it may send to Google certain limited location and usage data.

You can opt out of this individually through Settings.

Country of processing: USA        Google Privacy Policy
Legal basis for data transfer: Standard data protection clauses
Purpose: Providing location-based service

Security of your personal data

The security of your personal data is important to us, but remember that no method of transmission over the internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

Your rights under the GDPR

Under the European Data Protection Regulation, you have rights regarding your data and processing:

The right of access
You may access your personal information and make necessary changes in your account. If you would like to see which personal data we have obtained about you, you may exercise your right of access by submitting a request to us.

The right to rectification
When you believe we hold inaccurate or incomplete personal information about you, and you can`t correct it by yourself through your account, you may request us to make that changes for you. You may request us to modify, correct, supplement, erase or shield your information.

The right to erasure (the “right to be forgotten”)
You have the right to have your personal data erased under specific circumstances:

    • Personal data is no longer necessary for the purpose we originally collected or processed it.
    • When the legal basis for a particular processing is your explicit consent, you have the right to withdraw that consent. This does not affect past processing but does mean that we will no longer be allowed to process this data in the future. It may also result in us no longer being able to provide you with certain services.
    • When we process your data on the base of legitimate interests and there is no overriding legitimate interest for us to continue with the processing.
    • If you believe that we processed personal data unlawfully.
    • When we must erase personal data to comply with a legal ruling or obligation.

The right to restrict processing
You may ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure.

The right to data portability
You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if: the original processing was based on consent, the processing is by automated means, and the processing is based on the fulfilment of a contractual obligation.

The right to object
You have the right to object to our processing of your data where

    • Processing is based on legitimate interest;
    • Processing is for the purpose of direct marketing;
    • Processing is for the purposes of scientific or historic research; or
    • Processing involves automated decision-making and profiling.

The right not to be subject to automated decision-making

Whenever a decision about you is taken that is completely based on automated processing of your personal data, you have the right to request that decision be re-evaluated by a person. However, it will not apply if the processing is necessary for the performance of a contract, if it is authorized by the law, or if the processing is based on explicit consent.

Exercising your Data Protection Rights

You may exercise your rights by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible but no later than 30 days. Furthermore, you always have the right to contact the competent data protection authority. In the Netherlands, this is –  Autoriteit Persoonsgegevens.

Links to other websites

Our Service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time.
You are advised to review this Privacy Policy periodically. Changes to this Privacy Policy are effective when they are posted on this page.

Contact us

If you have any questions about this Privacy Policy, you can contact us by email: