REALITY
Privacy Policy (iOS)

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.”

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
• Identifier For Vendor
• 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）

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, ⅴ. 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;

• European Economic Area(EEA),United Kingdom: sixteen (16) years old
• South Korea: Fourteen (14) years old

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:

• OneSignal Inc. “OneSignal”
  https://onesignal.com/privacy_policy
  (To use the push notification feature of the App)
• Adjust GmbH. “Adjust”
  https://www.adjust.com/privacy-policy/
  (To identify and analyze the promotional effect of the App)
• Google LLC “Firebase”
  https://policies.google.com/privacy?hl=en
  (To analyze access for the purpose of log analysis, application improvement and marketing research of the App)
• Unity Technologies “Unity Cloud Diagnostics”
  https://unity3d.com/legal/privacy-policy
  (To examine the crash report for the App)

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.

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, ⅴ. 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.

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 "ⅴ. Controller of your personal data and its contacts."

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, ⅴ. 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. EU Representative

Company appointed the EU Representative as below;

Post: REALITY, Inc. EU Representative
PLANET // LEGAL
Neuer Wall 54, 20354 Hamburg, Germany
eu_representative@planit.legal

ⅴ. Controller of your personal data and its contacts

REALITY, Inc.
Roppongi Hills Tower, 6-10-1 Roppongi Minato-ku,
Tokyo, Japan
support-le@help.wrightflyer.net

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.

If you reside in any of the places listed below, the relevant terms shall apply;

1. United States (Last Reviewed Date: April 22, 2021)

This Privacy Notice Section 1 (“United States Privacy Notice”) supplements and modifies the “Basic Policy regarding the Protection of Personal Information” and the “Application Privacy Policy” of [REALITY, Inc.] (the “Company”) and applies solely to the user who resides in United States of America. We adopt this United States Privacy Notice to comply with the California Consumer Privacy Act of 2018 (CCPA), and unless otherwise specified, the terms used in this California Privacy Notice have the meaning defined in the CCPA. The term "sell" in this U.S. Privacy Notice refers only to the provision of information by the Information Collection Module to third parties.

1.1 Your personal information the Company collects

< 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
• Identifier For Vendor
• 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.

1.2 How the Company collects your personal information

• Directly from you. For example, from actions you take in the App or inquiries you make about the App.
• Automatically or Indirectly from you. For example, by automatically collecting information or observing your actions when you access the App or you link the App with External Services.

1.3 The purpose to collect and sell your personal information (The term “sell” refers only to the provision to third parties by the information collection module, the same as below)

We may use, sell, or disclose the personal information we collect for one or more of the following purposes:

(1) The purpose to collect your personal information

• Providing the services of the App
• Transferring the usage of the App
• Communication between users of the App
• Communication between you and the Company
• Achieving a secure and safe communication environment
• 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”

(2) The purpose to sell your personal information

• Studying, and analyzing the usage of the App
• Conducting marketing research and surveys

1.4 Sharing or sales of your personal information

(1) The Company may disclose your personal information for a business purpose as follows. We may share your personal information with third parties.

• Handling inquiries (including identity verification)
• Rectifying any violations of the Terms of Use
• Improving the App and fixing bugs

The third-party service provider to provide the service contemplated under the purpose to use your personal information as follows.

• GREE Inc. located in Japan.
  (To communicate with you to provide customer support for the App)
• Pole To Win Co., Ltd., and its affiliated company located in Singapore.
  (To communicate with you to provide customer support for the App)
• adish Co., Ltd. located in Japan
  (To rectify any violations of the Terms of Use and communicate with you)
• OneSignal Inc. “OneSignal”
  (To use the feature to send you push notification)
• Unity Technologies “Unity Cloud Diagnostics”
  (To investigate clash reports for the App)

(2) The Company may sell your personal information subject to your right to opt-out to those sales

• Adjust GmbH. “Adjust”
  (To identify and analyze the promotional effect of the App)
• Google LLC “Firebase”
  (To analyze the log of the App, To perform the access analysis for improvements and market research of the App, and To use the feature to send you push notification )

1.5 Your Rights and Choices

(1) You have the right to request from the controller access to and rectification or erasure of personal information 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 “6. Request for Disclosure, Etc.; Inquiries, ⅴ. Controller of your personal data and its contacts ”

(2) Personal Information Sales Opt-Out

DO NOT SELL MY PERSONAL INFORMATION

If you are the age of 13-15, you acknowledge and agree that your collected personal information is sold under this United States Privacy Notice by accessing the App.
You may opt-out of future sales at any time after opting-in to personal information sales. You have the right to direct us to not sell your personal information at any time (the “right to opt-out”)

IF YOU WANT THE COMPANY NOT TO SELL YOUR PERSONAL INFROMATION, PLEASE FOLLOW THE INSTRUCTION AS FOLLOWS:

• To opt-out the sale of your personal information to Adjust GmbH “Adjust”
  Please follow the instruction as specified in the “Forget Device” page operated by Adjust GmbH. You can access this “Forget Device” page from here
• To opt-out the sale of your personal information to Google LLC “Firebase”
  Please follow the opt-out instructions in the privacy policy operated by Google LLC. You can access the page from here.

Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, Company will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include personal information, if necessary to verify your identity and the nature of your request.