Nreal Privacy Policy

Last Updated: July 15, 2019
Nreal( ) makes mixed, and augmented reality products and operate a platform where users can download, interact with, and submit content and obtain services related to our products. Collectively, we describe our products and services—including our websites, mobile apps, platform, content, hardware and the services described further in our Terms of Service ( )—as our “Services.” This Privacy Policy explains how we treat information from or about our users, including how we collect, use, and share information in connection with our Services.

  1. What kind of information do we collect?
    Depending on which Services you use, we must process different kinds of information from or about you. Here’s how:
    Information You (and others) Give Us. We collect the information you (and others) give us when using our Services. For example:
    When you register to use our Services, we ask for information such as your name, email address, and phone number.
    You will have the ability to add information to your profile after registration.
    If you buy something on or through our Services, we collect information about the transaction. This can include your payment information, purchase activity, and shipping and contact details.
    We collect information about the people, content, and experiences you connect to and how you interact with them across our Services.
    When you post, share or communicate with us or other nreal users on our Services, we receive and store those communications and information associated with them, such as the date a post was created.
    When you communicate with nreal, you provide us with information like your email address.
    We collect content and information about content you create using our Services, such as your avatar, a picture you post, or an object you sculpt.
    We also collect content and information that other people provide when they use the Services. This can include information about you, like when they send us an abuse report that refers to or contains video of you.
    Information Automatically Collected About You When You Use Our Services. We also collect information automatically when you are connected to our Services. Depending on how you access and use our Services, we collect information such as:
    Information about your interactions with our Services, like information about the people, games, content, apps, features, or other experiences you interact with, including information collected through or from content provided by our third-party partners. For example, we may receive information about in-app purchases you have made in a game provided by a third-party developer;
    Information collected in or through cookies, local storage, pixels, and similar technologies.
    Information about how you access our Services, including information about the type of device you’re using (such as a headset, PC, TV, mobile, or other connected device), its configuration (such as your operating system and graphics processing unit), your browser, Internet Protocol (“IP”) address, and how your device is performing;
    Information about the features you interact with on our Services. For example, when you use our voice-search features, we process your voice commands so we can deliver the content or feature you’ve requested;
    Certain identifiers that may be unique to you. These identifiers include device and other identifiers, such as those from games and apps you use;
    Information about the games, content, or other apps installed on your device or provided through our Services, including from third parties;
    Location-related information, which can be derived from information such as your device’s IP address. If you’re using a mobile device, some of our Services collect information about the device’s precise location, which is derived from sources such as the device’s GPS signal and information about nearby Wi-Fi networks and cell towers;
    Information about your environment, physical movements, and dimensions when you use an MR device;
    Information we receive through device settings you choose, such as your photos or audio content.
    Third parties may also collect information about you through the Services, as described below.
    Information from other sources. We also receive additional information about you from third parties, including partners that provide us information that is publicly or commercially available, and may combine that information with the other information we collect about you.
  2. How do we use information?
    We use the information as set out below and to provide our Services to you and our partners. Here’s how:
    To provide and personalize our Services. We use the information we collect to provide you with our Services. For example, we use this information to:
    Provide you with hardware, content, games, apps, and other experiences;
    Create accounts and user profiles;
    Communicate with you about our Services;
    Enable user-to-user communications and other social services;
    Provide technical support;
    Notify you about updates to our Services; and
    Customize your experiences based on your activities, including the content, games, apps, and other experiences you interact with, the other online services you use, and other information we collect. This allows us to make your experience unique and relevant to you, for example by showing you content that is most relevant to you.
    To improve and develop your experience and our Services. We also use the information we collect to understand and improve our Services and to develop the MR ecosystem. For example, we use the information to:
    Solicit and analyze input and feedback about our Services;
    Identify and address technical issues on our Services;
    Conduct and learn from research about the ways in which people use our Services; and
    Improve services offered by others, such as third parties that offer content, games, apps and other experiences on our platform.
    To market to you. We use the information we collect to send you promotional messages and content and otherwise market to you on and off our Services. We also use this information to measure how users respond to our marketing efforts.
    To promote safety and security. We use the information we collect to help promote safety and security on and off our Services, such as by investigating suspicious activity or violations of our terms or policies and protecting our or others’ rights or property.
  3. How is information shared?
    Our Services help you engage with the MR ecosystem and others that interact with it. To provide and support our Services, information we have about you is shared in certain circumstances. Here is who can see information about you when you and others use our Services.
    Public Information. Certain information you post to your nreal profile, such as your nreal ID (also known as your nreal Username), your system-generated user ID, and avatar, will be public and visible to people on and off our Services. Your nreal ID is a unique identifier you choose to identify yourself on our Services. Your system-generated internal-ID is an opaque string of characters generated by the nreal system that identifies your nreal profile.
    Information you post to public areas of our Services, such as a forum, blog, or other community tool, will also be visible to people on and off our Services. If you post information to these interactive features, it will be publicly available. Certain information associated with your public posts, such as the time of your post, may also be published and publicly available.
    Content others share about you. You should consider who you choose to share with, because people who are able to see your activity, content, or information on our Services may choose to share it with others on and off our Services. For example, when you interact with others in a multiplayer game, another player could choose to share screenshots – including what you are doing in the game – on social networking sites.
    Apps, Developers, and Other Online Content Providers on our Services. You can interact with third-party content, games, apps, and other experiences through our Services. We may share information about you with these partners so they can provide you with the experiences you’ve requested, such as:
    Information in your nreal profile and about how you use our Services. For example, we may provide a third-party gaming experience with information about people you commonly interact with on our Services so they can offer to pair you in a social experience. We may also share information about individual abuse reports or abuse statistics on our Services, so we can help develop a safe and enjoyable MR ecosystem.
    Information about your interaction with the third-party service, such as how long you have interacted with content or how far you have progressed in a game.
    Any other information you choose to share with the third party.
    Third-party content providers may also collect information from you directly through the experiences they provide. Please note that any information you share with these (or other) third parties will be subject to those third parties’ own privacy policies, not this one.
    Service providers. We share the information we collect with vendors, service providers, researchers and other partners, who work at our direction to support the Services (such as hosting our Services, fulfilling orders, facilitating payments, analyzing the way people use our Services, processing credit card payments, providing customer service, or sending electronic communications for us).
    Other parties in connection with certain business transactions. In the event that the ownership of nreal(or any portion of our assets) changes as a result of a merger, acquisition, or in the event of a bankruptcy, information from or about you or your device may be transferred to another company.
    Permission. We may share information about you for any other purpose you choose.
    Law enforcement or legal requests. We share information with law enforcement or in response to legal requests in the circumstances outlined in Section 6 below.
    We also share de-identified or aggregate data with others. De-identified data means information where we have removed your name and other data that could reasonably be used to identify you. Aggregate data is data that has been combined with other data so that it doesn’t identify any specific person. For example, we provide developers with aggregated statistics about the number of people from a particular region that use our Services, so developers can create content tailored for people in that market.
  4. Third Parties that Provide Content, Marketing, or Functionality on Our Services
    Some of the content, marketing, and functionality on our Services may be provided by third parties that are not affiliated with us. For example, we work with companies that help us understand how people use our Services.
    Other companies may collect information on or through our Services to market to you on or off of our Services. These and other third parties may collect information about your use of our Services, including through the use of cookies, device IDs, local storage, pixels and other technologies, and this information may be collected over time and combined with information collected on different websites and online services.
  5. Data retention and deletion
    We store data that identifies you until it is no longer necessary to provide our Services or your account is deleted, whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. For example, we may retain certain purchase information for accounting and tax purposes even after you have deleted your account.
    When you delete your account, we delete things you have posted and information about apps and entitlements you have downloaded, and you will not be able to recover that information later. Information that others have shared about you is not part of your account and will not be deleted when you delete your account.
  6. How do we respond to legal requests and preventing harm?
    We access, preserve and share information with regulators, law enforcement or others:
    In response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of the China where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
    Information we receive about you, including financial transaction data related to purchases made on or through our Services, can be accessed, processed and retained for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from accounts disabled for violations of our terms for at least a year to prevent repeat abuse or other term violations.
  7. How we operate and transfer data as part of our global services
    We share information globally and externally with our partners and with those you connect and share with around the world. Your information may, for example, be transferred or transmitted to, or stored and processed in the China or other countries outside of where you live for the purposes described in this policy.
  8. How will we notify you of changes to this policy?
    If we make changes to this Privacy Policy, we will provide notice of such changes as appropriate, such as by sending you an email notification to the address you’ve provided, and/or providing notice through the Services. If we make an administrative change, we may update the “Last Updated” date at the top of this Privacy Policy.
  9. Contacting Us
    If you have questions about this Privacy Policy, please contact us at .