REALITY
Privacy Policy (iOS)

i. Scope

This “REALITY” Privacy Policy for iOS (this “Policy”) provides for the handling of personal information on the “REALITY” application (the “App”) 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.” In addition, "8. Terms for specific Countries" applies to customers residing in the United States and South Korea.

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. Acquisition of Phone Numbers

The App will acquire and use your phone number for the purpose of logging in and displaying your REALITY account as a recommended user to other users. You can set whether or not to be displayed as a recommended user within the App.

iii. Retrieval of contacts data registered on the device

The App provides a function that allows a customer to upload the contacts on the customer's device, and if there is a user using the App in the contacts, this user can be displayed as a recommended user in the App. This functionality is only available when the customer uploads the contacts, and accesses and obtains the names and phone numbers (including information of individuals who are not users of the App) registered in the contacts on the customer's device.
The contacts information obtained by this function will be used only for the purpose of displaying recommended users within the App.

ⅳ. 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
• Phone number
• Contacts data registered in the device (name and phone number)
• Information provided by you when making an inquiry
• Payment information
• Usage of the App
• Content of communication that takes place on the App
• Credit card information for payment

< 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
• Device information(Device ID/Device name/Manufacturer/OS, etc.)
• Identifier For Vendor
• Identifier For Advertisers

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

ⅴ. Purpose of use of the information described in 2 ⅳ

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
• Display of recommended users within 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
• Paying fees with a credit card
• Paying Distribution Revenue
• Handling inquiries (including identity verification)
• Providing information to the third parties set forth in “4. Provision to Third Parties; Information Collection Module”

ⅵ. 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

(1) 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.

(2) When credit card payment is used in the App, the necessary information for payment will be provided to Stripe Japan, Inc. and Stripe, Inc. stores and manages credit card information you enter, and the Company does not store the credit card information.

(3) When the distribution revenue corresponding to live streaming on the App, is paid by the Company through the service of Payoneer Japan Limited., the Company will provide Payoneer Japan Limited. and Payoneer Inc. with the information necessary for the payment of the distribution revenue. In addition, upon request from Payoneer Japan Limited., the Company will provide Payoneer Japan Limited. and Payoneer Inc. with information regarding your use of the App.

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”
  Privacy Policy
  (To use the push notification feature of the App)
• Adjust GmbH. “Adjust”
  Privacy Policy
  (To identify and analyze the promotional effect of the App)
  Opt-out: https://www.adjust.com/forget-device/
• Google LLC “Firebase”
  Privacy Policy
  (To analyze access for the purpose of log analysis, application improvement and marketing research of the App)
• Unity Technologies “Unity Cloud Diagnostics”
  Privacy Policy
  (To examine the crash report for the App)
• GIPHY, Inc. ”GIPHY”
  Privacy Policy
  (To provide the function of sending and receiving GIF images in the App)
• Glossom, Inc. ”Adfurikun”
  Privacy Policy
  (To display advertisement to users in the App)
• Bytedance Pte. Ltd. ”Pangle”
  Privacy Policy
  (To display advertisement to users in the App)
• Google LLC ”AdMob”
  Privacy Policy
  (To display advertisement to users in the App)
• Unity Technologies ”Unity Ads”
  Privacy Policy
  (To display advertisement to users in the App)
• AppLovin Corporation ”AppLovin”
  Privacy Policy
  (To display advertisement to users in the App)
• Meta Platforms, Inc. “Meta Audience Network”
  Privacy Policy
  (To display advertisement to users in 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.

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 Gate Tower, 6-11-1 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 Gate Tower, 6-11-1 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: July 3, 2023)

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 Privacy Rights Act of 2023 (CPRA), and unless otherwise specified, the terms used in this California Privacy Notice have the meaning defined in the CPRA. 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
• Phone number
• Contacts data registered in the device (name and phone number)
• Information provided by you when making an inquiry
• Payment information
• Usage of the App
• Content of communication that takes place on the App
• Credit card information for payment

< 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
• Device information(Device ID/Device name/Manufacturer/OS, etc.)
• Identifier For Vendor
• Identifier For Advertisers

For the purpose of studying, analyzing and improving the use of the App, the Company may associate the Identifier 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 or pays fees with a credit card.
• 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
• Display of recommended users within 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
• Paying fees with a credit card
• Paying Distribution Revenue
• 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
• Advertisement placement and their optimization 

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.

• Providing the services of the App
• Display of recommended users within the App
• Handling inquiries (including identity verification)
• Achieving a secure and safe communication environment
• Rectifying any violations of the Terms of Use
• Improving the App and fixing bugs
• Paying fees with a credit card
• Paying Distribution Revenue

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 provide the service of the App)
• ExPlay, Inc. located in Japan.
  (To communicate with you to provide customer support for the App, to rectify any violations of the Terms of Use and communicate with you )
• PTW Japan Co., Ltd. and its affiliated companies. Located in Japan and Malaysia and India.
  (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)
• Besedo Ltd. located in Malta
  (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)
• Stripe Japan, Inc. and Stripe, Inc.
  (To pay fees with a credit card)
• Payoneer Japan Limited. and Payoneer Inc.
  (To pay the distribution revenue)
• GIPHY, Inc. located in United States of America.
  (To provide the function of sending and receiving GIF images in the App)
•  Glossom, Inc.
  (To identify and analyze the promotional effect of the App)
•  Adjust GmbH. “Adjust”
  (To identify and analyze the promotional effect of the App)
• Mirai Translate, Inc. located in Japan.
  (To perform translations)
• Twilio Japan G.K. and Twilio Inc. located in Japan and United States of America.
  (To perform authentication and login process by phone number when linking phone numbers)

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

• 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 )
•  Glossom, Inc. ”Adfurikun”
  (To display advertisement to users in the App)
•  Bytedance Pte. Ltd. ”Pangle”
  (To display advertisement to users in the App)
•  Google LLC ”AdMob”
  (To display advertisement to users in the App)
•  Unity Technologies ”Unity Ads”
  (To display advertisement to users in the App)
•  AppLovin Corporation ”AppLovin”
  (To display advertisement to users in the App)
• Meta Platforms, Inc. “Meta Audience Network”
  (To display advertisement to users in the App)  

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 Google LLC “Firebase”
  Please follow the opt-out instructions in the privacy policy operated by Google LLC. You can access the page from here.
• To opt-out the sale of your personal information to Glossom, Inc. ”Adfurikun”
  Please follow the opt-out instructions in the privacy policy operated by Glossom, Inc. You can access the page from here.
• To opt-out the sale of your personal information to Bytedance Pte. Ltd. ”Pangle”
  Please follow the opt-out instructions in the privacy policy operated by Bytedance Pte. Ltd. You can access the page from here.
• To opt-out the sale of your personal information to Google LLC ”AdMob”
  Please follow the opt-out instructions in the privacy policy operated by Google LLC. You can access the page from here.
• To opt-out the sale of your personal information to Unity Technologies ”Unity Ads”
  Please follow the opt-out instructions in the privacy policy operated by Unity Technologies. You can access the page from here.
• To opt-out the sale of your personal information to AppLovin Corporation ”AppLovin”
  Please follow the opt-out instructions in the privacy policy operated by AppLovin Corporation. You can access the page from here.
• To opt-out the sale of your personal information to Meta Platforms, Inc. “Meta Audience Network”
  Please follow the opt-out instructions in the privacy policy operated by Meta Platforms, Inc. 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.

2. South Korea (Last Reviewed Date: July 3, 2023)

This Privacy Notice Section 2 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 South Korea. We adopt this section to comply with the Personal Information Protection Act of South Korea (PIPA), and unless otherwise specified, the terms used in this section have the meaning defined in the PIPA.

2.1 Provision of Personal Information to Third Parties

(1)The Company will not provide your personal information to third parties, processing your personal information within the scope clearly indicated at the time of acquisition of your personal information.

(2)However, only the minimum necessary personal information will be provided to third parties for the purposes described below in order to provide smooth service.

2.2 Information Collection Modules

The App includes the following information collection modules provided by third parties.

*Information is collected by information collection module, and the Company is not related to or has no control over collection and processing of such personal information.

2.3 Receipt of Personal Information from Third Parties

(1) We receive and use the following personal information from third parties.

2.4 Delegation of Personal Information

(1) In using the App, you delegate your personal information to the following companies.

2.5 Out-of-Country Transfer

(1) In using the App, personal information will be transferred outside of Korea as follows.

2.6 Retention Period and Destruction Procedures and Methods of Personal Information

(1) When personal information is no longer needed, such as when the retention period of personal information has expired or the purpose of processing has been achieved, we will destroy such personal information without delay.

(2) The Company will use personal information within the retention period and usage period of personal information that the customer agreed to when using the App. If you withdraw your consent to the acquisition and use of your personal information, we will destroy your personal information without delay upon the achievement of the purpose of use or the expiration of the period of time for which such information is required.

Our Information Retention Policy

(3) The Company destroy personal information recorded and stored in electronic file form using methods that do not allow the records to be reproduced, and personal information recorded and stored on paper is destroyed by crushing it in a pulverizer.