PRIVACY POLICY — Addreality

PRIVACY POLICY

1. Introduction

Addreality LLC respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how Addreality LLC look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This privacy policy is meant to help you understand what data we collect, why we collect it and how we process it.

This privacy policy fully complies with the provisions of GDPR Regulation - Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) and Russian Federal Law of 27 July 2006 N 152-FZ «On personal data».

2. Definitions

The Policy

The Policy means this Privacy policy (also referred below as “Privacy policy”);

Addreality

Addreality means Addreality Limited Liability Company (Addreality LLC, OGRN N1137847149626) collectively referred to as “Addreality”, “we”, “us” or “our” in this Privacy policy;

User

The User means a legal or natural person who uses Addreality services (works, products, collectively referred hereinafter – “services”) or the Software of Addreality, including throw the Addreality website, collectively referred to as “you”, “your” or “yours” in this Privacy policy;

Addreality website

the Addreality website means the website in the Internet, located at addreality.com, all rights for its administration are hold by Addreality;

Software

the Software means the complex software “Addreality” (computer program “Addreality Platform”), consisting of three computer program the “Addreality Player”, the “Addreality Designer” and the “Addreality Manager”. Where “Addreality Manager” is a management program for all computer programs mentioned above and can run one or more “Addreality Sphere Player” instances. All exclusive rights for the Software are belong to Addreality according the law and (or) the related deals (agreements, contracts);

Agreement

The Agreement means as relevant: (a) the End-User License Agreement for Software usage, which defines the order of using of the Software, included as a component (shrinkwrap license), on a simple (nonexclusive) license basis, accepted by the Client upon installing and (or) starting of Software usage; (b) other license agreement concerning the Software usage between Addreality and the User; (C) any other agreement between Addreality and the User, including the Addreality website terms and conditions.

Legitimate Interest

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product/Software and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of the Agreement

Performance of the Agreement means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Fundamental condition

The processing of your personal data in relation to your use of the Addreality website and/or use of the Software or services, will be subject to this policy. If you disagree with any part, of this policy then you may not access the Addreality website and/or use the Software or services. Should you disagree with any provision of this Policy you shall cease using the Addreality website or any Software/Services immediately. If you are using the Addreality website, Software or services in your own name or on behalf of any entity, you acknowledge this Policy on your or such entity’s behalf (when applicable).

3. General Provisions

3.1. The Controller

Addreality is the controller, processors and responsible for User’s personal data. Being the controller Addreality independently determines the personal data processing purposes and means.

Contact details of the controller: Addreality Limited Liability Company (Addreality LLC), a legal entity under the laws of the Russian Federation, incorporated on 10th of April 2013 under primary national registration number (OGRN) N1137847149626, located at Office 404, bld. 4A, Kantemirovskaya street, St. Petersburg, Russian Federation, 194100.

User’s Support: support@addreality.com

3.2. Data protection officer (DPO)

Being the controller, Addreality appoints a data protection officer (DPO), who is responsible for overseeing questions in relation to User’s data protection.

If User has any questions in relation to this Privacy policy, User is entitled to contact using the details set out below: Full name and contact details of the person authorized by the controller and responsible for personal data procession: Data protection officer (DPO), Alexey Golovishnikov, email: a.golovishnikov@addreality.com, tel.: +7 (800) 333-73-17.

Users, being a citizens or residents of European Union, have the right to make a complaint at any time to applicable to you Data Protection Authority and can find contact details of their National Data Protection Authority online at: http://ec.europa.eu/justice/article29/structure/data-protection-authorities/index_en.htm

Addreality would, however, appreciate the chance to deal with your concerns before you approach the DPA so please contact us or our DPO in the first instance.

3.3. Third-party links

This Addreality website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share User’s data. Addreality does not control these third-party websites and is not responsible for their privacy statements. When you leave Addreality website, Addreality encourage you to read the privacy policy of every website you visit.

4. Types, purposes, metods and periods of personal data processing

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Addreality may collect, use, store and transfer different kinds of personal data about you (User) which we have grouped together follows:

Identity Data includes first name, last name, username or similar identifier, official capacity and place of employment.

Contact Data includes correspondence address, email address and telephone numbers.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, browser plugin types and versions, device type, operating system and platform and other technology on the devices you use to access this Addreality website.

Usage Data includes information about how you use our website, products and services.

Addreality also may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, Addreality may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if Addreality combines or connects Aggregated Data with your personal data so that it can directly or indirectly identify you, Addreality treats the combined data as personal data which will be used in accordance with this privacy policy.

Addreality does not collect or process any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor does Addreality collect or process any information about criminal convictions and offences.

If you fail to provide personal data

Addreality needs to collect and process personal data under the terms of the Agreement we have with you and if you fail to provide that data when requested, Addreality may not be able to perform the Agreement we have or are trying to enter into with you (in particular, to provide you identity verification services). In this case, Addreality may have to cancel a service and the Agreement you have with Addreality, but you will be notified if this is the case at the time.

Addreality may use different methods to collect data from and about you including through:

Direct interactions. You may give to Addreality your Identity and Contact Data by filling in online forms provided on the Addreality website. This includes personal data you provide when you: (а) create an account on our Addreality website; (b) submit your information for identity verification.

Automated technologies or interactions. As you interact with our Addreality website, Addreality may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. Addreality collects this personal data by using cookies, and other similar technologies. Please see Addreality cookie policy in section 10 of this privacy policy.

Third parties or publicly available sources. Addreality may receive personal data about you from various third parties, namely Technical Data from analytics providers such as Google Analytics, Yandex.Metrika and Zoho CRM Advanced Analytics. This allows Addreality to record and analyze how you use Addreality Software and Services. Addreality uses this data on the basis of our legitimate interest as a business in improving our understanding of User’s needs and preferences in order to constantly enhance our services and improve our Software and Services. User may at any time disable collection of your data by these analytics providers, as described on their profile websites.

How Addreality may use your personal data

Addreality will only use your personal data when the law allows us to. Most commonly, Addreality will use your personal data in the following circumstances:

Where we need to perform the Agreement, we have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Where we need to comply with a legal or regulatory obligation.

User is kindly asked to see information below to find out more about the types of lawful basis that we will rely on to process your personal data. Generally, Addreality does not rely on consent as a legal basis for processing your personal data as we shall process it for the performance of the Agreement.

Methods of your personal data processing:

Collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, examination, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, sampling, erasure or destruction.

Period of your personal data processing:

(a) If you are a citizen of a European Union country, your personal data processing period ends in 5 (five) years from the termination of interaction between you and Addreality in the Agreement framework. The personal data storage period may be extended from 5 (five) to 7 (seven) years upon the competent authority request.

(b) If you are not a citizen of a European Union country, your personal data processing period for such is unlimited and personal data may be processed by Addreality after the termination of the Agreement.

In some circumstances you can ask us to delete your data. Please note that if personal data is erased at your request, we will only retain such copies of the information as are necessary to protect our or third party legitimate interests, comply with governmental orders, resolve disputes, troubleshoot problems, or enforce any agreement you have entered into with us.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

5. Purposes for which Addreality may use your personal data

Addreality has set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Addreality has also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new user on Addreality website. (a) Identity Data

(b) Contact Data
Performance by us of the Agreement with you.
To manage our relationship with you which will include:

(a) Notifying you about changes to our Software or Addreality website terms of use or privacy policy;

(b) Asking you to leave a review or take a survey, providing you with our email newsletters and other email letters in case you are subscribed;

(с) Your Identification on Addreality website for our services and Software providing.
(a) Identity Data

(b) Contact Data
(a) Performance of the Agreement with you;

(b) Necessary to comply with a legal obligation;

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our Software/services).
To administer and protect our business and Addreality website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). (a) Identity Data

(b) Contact Data

(с) Technical data

(d) Usage data
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud)

(b) Necessary to comply with a legal obligation
To use data analytics to improve our Addreality website, Software and services, User’s relationships and experiences. (с) Technical data

(d) Usage data
Necessary for our legitimate interests (to define types of Users for our services and Software, to keep our Addreality website updated and relevant, to develop our business and to inform our marketing strategy)

Change of purpose

Addreality will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Where Addreality may store your information

We store your personal data on servers located within the Russian Federation. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

7. Data security

Addreality has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, Addreality limits access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on instructions of Addreality and they are subject to a duty of confidentiality.

Addreality has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Numerous studies have established that data stored in the cloud is less likely to be lost, deleted or leaked than data stored on a personal computer. All Addreality’s data is fully encrypted at rest and in transit, and Addreality employs state-of-the-art firewall and back-up technology. All Addreality’s data is continuously backed up in several high security access-controlled data centers in different locations.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

(a) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(d) Object to processing Tof your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(f) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform the Agreement with you.
(g) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

9. OTHER CONDITIONS

What Addreality may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

No fee required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).

10. Version of this Privacy policy

Last updated: November 25, 2019