REALITY
Privacy Policy (iOS)

1. Privacy Policy

i. Scope

This “REALITY” Privacy Policy (this “Policy”) provides for the handling of personal information on the “REALITY” application (the “App”) for mobile devices (limited to the mobile devices that can use the “iOS” OS provided by Apple Inc.; the “Mobile Devices”) provided by [REALITY, Inc.] (the “Company”). With regard to matters that are not provided for in this Policy, please also review the “Basic Policy regarding the Protection of Personal Information.”

2. Collection of Personal Information; Purpose of Use

i. Collection of facial expression data

In order to make the avatar work, this App will use TrueDepth API provided by Apple Inc. to collect facial expression data, but it will not be used for any purpose other than to make the avatar work, and the Company will not store the data or share it with any third party.

ii. List of other information that will be collected

The Company may collect the following information from you in connection with the provision of the App:

< The information you directly provide to Company >

  • Nicknames, self-introductions and images on your profile
  • Date of birth
  • Information provided by you when making an inquiry
  • Payment information
  • Usage of the App
  • Content of communication that takes place on the App

< The information automatically collected when working with external services such as Twitter (hereinafter referred to as "External Services") >

  • User ID for External Services
  • Names and nicknames used in External Services
  • Profile images used in External Services
  • Other member information on External Services (friend information, etc.)

< The information automatically collected from you >

  • IP address
  • Advertising identifier
  • Identification For Advertisers
For the purpose of studying, analyzing and improving the use of the App, the Company may associate the Identification For Advertisers with the internal identifier we have given to you.

ⅲ. Purpose of use of the information described in 2 ii

The Company will use the collected information for the following purposes:

  • Providing the services of the App
  • Transferring the usage of the App
  • Communication between users of the App
  • Achieving a secure and safe communication environment
  • Communication between you and the Company
  • Studying and analyzing the usage of the App
  • Conducting marketing research and surveys
  • Improving the App and fixing bugs
  • Advertisement placement and their optimization
  • Rectifying any violations of the Terms of Use
  • Handling inquiries (including identity verification)
  • Providing information to the third parties set forth in “4. Provision to Third Parties; Information Collection Module”

iv. Legal basis

The legal basis for the processing of your personal data is;

  • Your consent.
  • Legitimate interests（to improve and enhance user experience such as answering inquiries from you）

3. Our Policy regarding Children

The App is not intended for children under 13 years of age, and we do not knowingly collect or solicit personal data from anyone under the age of 13 or knowingly allow such persons to use the App. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number or e-mail address. No one under the age of 13 may provide any personal data. In the event that we learn that we have collected personal data from a child under the age of 13, we will delete that data. If you believe that we might have received data from or about a child under the age of 13, please contact us at the following "6.Request for Disclosure, Etc.; Inquiries, iv. Controller of your personal data and its contacts". As for those who lives in the country or region listed below, we do not process personal data from anyone under the following age;

  • South Korea: Fourteen (14) years old

4. Provision to Third Parties; Information Collection Module

i. Provision to third parties

In the cases set forth in "4. Provision to Third Parties" of the “Basic Policy regarding the Protection of Personal Information,” the Company may disclose personal data to third parties inside and outside the country.

ii. Information collection module

The App contains the following information collection modules provided by the following third parties for purposes such as providing the features included in the App, displaying advertisements, and analyzing usage. With regard to the purpose of use of the information that will be collected or has been collected through such information collection module, please review the privacy policy that has been provided by each company providing an information collection module:

iii. Disclosure to third parties outside of the country

When you agree to this Policy, you acknowledge that the collected data set forth in this Policy may be transferred outside of your country or region and that there may be cases where the country or region to which the data is transferred does not have laws or regulations imposing protection obligations that are equal to or greater than the laws and regulations regarding personal data and other privacy protection in your country or region. You agree that the Company will disclose the collected data set forth in this Policy to its parent company, GREE, Inc., and its affiliates as well as its approved subcontractors, media, and/or ad agents located in Japan, or the country other than member states of EEA where the approved subcontractor, media or ad agents establish its hub for the purpose of use set forth in this Policy.

The company will outsource the answering inquiry from you to Pole to Win Co., Ltd. located in Singapore and adish Co., Ltd. located in Japan.

5. Method of Notices, Announcements, or Obtaining Consent; Method of User Involvement

i. Notices and announcements

This Policy is posted and announced on the initial startup screen and the help page on the App as well as on the privacy policy link that is found on the download page for the App in the app store (App Store, etc.). The Company may amend this Policy, and any important changes will be announced on the App or each posting location. The amended Policy will become effective when it is posted on the App or each posting location.

ⅱ. Method for obtaining consent

Please use the App after you have reviewed and agreed to the Terms of Use and this Policy. By using the App (in the case of an amended Policy, by continuing to use the App after the amendment), you will be deemed to have agreed to this Policy. If you do not agree to this Policy (including the amended Policy), you must not use the App. Notwithstanding the foregoing, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. In the case of withdrawing your consent, please contact us after confirming the following "6.Request for Disclosure, Etc.; Inquiries, iv. Controller of your personal data and its contacts." section.

ⅲ. Suspension of collection and transmission of information

You may stop the collection and transmission of information by deleting (uninstalling) the App from the Mobile Devices.

6. Request for Disclosure, Etc.; Inquiries

ⅰ. Request for disclosure, correction, addition, deletion, suspension of use, etc.

You have the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject and to object to processing as well as the right to data portability. If you or your agent makes a request concerning your right listed above, the Company will comply with such request without delay to the extent possible in accordance with laws and regulations. With regard to such requests, please review "iv. Controller of your personal data and its contacts."

You have the right to lodge a complaint with a supervisory authority which governs your habitual residence with respect to processing of your personal data.

ii. Inquiries

If you wish to make an inquiry, to discuss, or to file a complaint with regard to the handling of personal data in connection with the App, please contact us at "6.Request for Disclosure, Etc.; Inquiries, iv. Controller of your personal data and its contacts".

iii. Data Protection Officers（DPO）

Company elected the data protection officer is involved, properly and in a timely manner, in all issues which relate to the protection of personal data.
Post: Data Protection Officer
GREE, Inc.
Roppongi Hills Mori Tower, 6-10-1 Roppongi, Minato-ku,
Tokyo, Japan
dpo@gree.net

iv. Controller of your personal data and its contacts

REALITY, Inc.
Roppongi Hills Tower, 6-10-1 Roppongi Minato-ku,
Tokyo, Japan
support-en@reality.app

7. Administration Policy

i. Amendment of this Privacy Policy

The terms of this Privacy Policy may be revised or amended. Unless otherwise specified by the Company, the revised or amended Privacy Policy will come into effect when it is posted on the App or each posting location.

ii. Retention Policy

Except as the case being necessary for the compliance of applicable law, regulation or order by the government, court, or other applicable authority, the Personal data will be deleted when the personal data becomes unnecessary to achieve the purpose of use as specified in Section 2 iii.

iii. Others

Please note that if you do not provide Company with the latest and accurate information of yourself, you may not receive appropriate service.

Established on July 31, 2018

Revised on October 7, 2020

Revised on December 7, 2020

Revised on March 22, 2021