Reality+ Privacy Policy

You should read this policy in full, but here are the key points:

• When you download Reality + or utilise App Clips or Instant Apps you may share limited information with us and with Apple or Google (as the case may be) about you - such as your device type. For information as to what information Apple or Google collect when you utilise an App Clip or Instant App please see their privacy policies, for which we are not responsible.

• We also collect certain information about how you use our Apps, in addition to details of the device you are on, such as how long you’re on the service and we can infer your location when you access the content from those scans (rather than from your library) as we will know the QR code or NFC you have scanned to operate the service. However, we do not know who you are, or collect personal data about you by using our Apps.

• We need to collect, store, and process the non-personalised limited data described above to provide you with the service and to provide a safe, reliable and legal service and to understand how our Apps are used, so we can make them better.

So, in essence, we know very little about you when you use our Apps. We collect and monitor how our Apps are being used through collecting anonymous information such as details of when our Apps are being accessed, how long our Apps are being used and we may infer your location because we know where the QR Code or NFC is located which you are accessing to make use of our Apps. So other than this anonymised usage information and device type we know very little about you!

Reality+ Master Privacy Statement

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how we, vTime Limited, collect and how we may process limited aspects of your data through your use of our app called “Reality +” or the AppClip (iOS) or Instant App (Android), which is related to it (together “our Apps”). Our AppClip and Instant App are smaller versions of the full Reality+ app and operate using less, non-personalised information about you, and your device when you access them, without you having to download the full Reality+ app.

Our Apps and related services are not intended for children (anyone under 13 years of age for this purpose) and we do not knowingly collect data relating to children under 13. You may from time to time be requested to verify your age as set out in our Age Verification Policy which can be found in our terms and conditions.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them. Please read our terms and conditions in full to understand the terms you must agree to in order to use our Apps and related services.

Please note that if you have downloaded our other apps known as “vTime XR” or “vTag” or access our related websites for those apps, those websites and apps have separate privacy policies and terms and conditions that relate to their use and we would request and encourage you to read those terms if you wish to use “vTime XR” or “vTag”. If you don’t accept those terms you should not use vTime XR or vTag or visit the related websites.

CONTROLLER

vTime Limited is the controller and responsible for your personal data (collectively referred to as ”Company”, “we”, “us” or “our” in this privacy policy).

We have appointed a privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS

Our full details are:

Company name: vTime Limited

Name and title of privacy manager: Stephen Houston, General Counsel and Director

Email address: data@vTime.net

Postal address: 27 Parliament Street, Liverpool, UK. L8 5RN

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on January 10th, 2022 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

Our Apps and related services may from time to time include links to third-party apps, websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party apps or websites and are not responsible for their privacy statements. When you leave our Apps, we encourage you to read the privacy policy of every app and website you use and their terms and conditions.

2. THE DATA WE COLLECT ABOUT YOU

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).

We do not intend to collect any personal information about you which is not anonymised by your using our Apps. However, if you do provide us at any time with any of your personal data, for example, if you contact us, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, last name, username or similar identifier, title, and date of birth. We do not collect this information from the use of our Apps, however. You would have to disclose this to us by other means.

Location Data we may infer your device location and potentially therefore your whereabouts as you use our Apps because we will know the location of the QR code or NFC you have scanned to operate the service. However, as we will only know your device ID we will not know who you are or process any of your personal data in doing so.

Contact Data includes your phone number and email address. We do not collect this information from the use of our Apps, however. You would have to disclose this to us by other means.

Technical Data includes internet protocol (IP) address, login data, device type and version, browser type and version (if relevant), time zone setting and location, browser plug-in types and versions (if relevant), operating system and platform and other technology on the devices you use to access the Apps and related services. Use of our Apps will only collect information about your device and potentially the location of your device by inference, as mentioned above, but we do not collect personal data via the use of our Apps, only anonymised data.

Profile Data includes your username and password, your interests, preferences, feedback and survey responses. We do not collect this information from the use of our Apps, however. You would have to disclose this to us by other means.

Usage Data includes when and where you log on to our Apps, what device you use and how long you spend on the Apps. However, we will not be collecting or processing your personal data, all such usage data is anonymised.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. We do not collect this information from the use of our Apps, however. You would have to disclose this to us by other means.

We do 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, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App at a specific location or accessing a specific feature. However, if we would ever combine or connect aggregated data with your personal data, disclosed to us any other means, so that it can directly or indirectly identify you, we would treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect or seek to collect 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 do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you (such as our terms and conditions) and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you the vTime services through our Apps). In this case, we may have to cancel the services you have with us, but we will notify you if this is the case at the time if we have contact details for you.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

While our Apps do not collect personal data about you, we use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• create an account on any of our apps, services or website, other than Reality + ;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.

Automated technologies or interactions. As you interact with our Apps and/or related website or services, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our vTime cookie policy on our website www.vtime.net for further details.

Location data. We may infer your device location and potentially therefore your whereabouts as you use our Apps because we will know the location of the QR code or NFC you have scanned to operate the service (this won’t be the case if you access the content from your library). However, as we will only know your device ID we will not know who you are or process any of your personal data in doing so.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

• analytics providers such as Google or Facebook
• search information providers such as Google
• platform holders, such as Apple

But we would be unable to connect this personal data to the data collected from your use of our Apps because this is anonymised.

4. HOW WE USE YOUR PERSONAL DATA

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

• Where we need to perform the contract we are about to enter into or have entered into with you through our terms and conditions.
• 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.
• The types of lawful basis that we will rely on to process your personal data are set out in the table below.

Generally, we do not rely on consent, or consent alone, as a legal basis for processing your personal data other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing or consent for other purposes at any time by contacting us through data@vtime.net.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which legal bases we rely on to do so. We have 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 via data@vtime.net 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.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Location, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you if you disclose your Identity to us. This is how we decide which products, services and offers may be relevant for you (we call this marketing). However, we cannot discern your identity through the use of our Reality + app or our related AppClips or Instant Apps.

You will receive marketing communications from us if you have requested such information from us and have disclosed your contact details and Identity to us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data, if we have any, with any company outside the vTime group of companies for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by adjusting your marketing preferences or by following the opt-out links on any marketing message sent to you, or by contacting us at any time.

Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us by other means. But you can contact us to ask about the personal information we do hold about you by contacting us through data@vtime.net.

COOKIES

You can set your browser to refuse all or some browser cookies or similar technologies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our services and website may become inaccessible or not function properly. For more information, read our full Cookie Policy which can be found here.

CHANGE OF PURPOSE

We will only use your personal data, if we have any, 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 if we know your ID and contact information 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 and our terms and conditions or where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third Parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy and our terms and conditions.

We require all Third Parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes unless you have agreed or consented to them doing so, and only permit them to process your personal data for specified purposes and in accordance with our instructions.

If you have registered to use any of our services using other social media platforms or other external Third Parties (such as Facebook, Instagram, Google, Apple), for example through single sign-on, you or they will provide us with your username and public profile. In return, we share certain Technical Data with those external Third Parties such as your IDFA (on iOS) or Advertiser ID (on Android) and the referring URL for the purposes set out in the table above.

For all users certain Technical Data such as the IDFA (on iOS) or Advertiser ID (on Android) associated with a user is sent to Facebook or App Flier, in order to attribute the source of a user of our apps (other than Reality +), unless they have opted-out on their device. We may share this information with other external Third Parties such as social media platforms or advertisers, too. In this way, we can verify if a user has accessed our apps from Facebook or other platforms and we can then analyse how effective our ads on those platforms have been and we can use that data to bring you more relevant ads and to improve your experience. The use of this data and its processing by Facebook or App Flier or another external Third Party will be under their terms and conditions and privacy policy.

Where you share content on other social media platforms, the relevant, username and accompanying text and audio file will be shared on that platform or, in the case of sharing via instant messaging platforms such as WhatsApp, a link to the content will be shared.

You can access Facebook’s, AppFlyer’s and other relevant external Third Party’s terms and conditions and privacy policies in the Glossary section below.

We also incorporate various third-party plugins and libraries of software into some of our apps in order to build their functionality. A full list can be found here. Based upon the licence agreements and supporting documentation provided by them to us, we believe they do not share any personal data with third parties. However, if you are concerned, you should familiarise yourself with their individual privacy policies. See also the section below entitled EXTERNAL THIRD PARTIES for further information on who we might share your data with and in what circumstances.

6. INTERNATIONAL TRANSFERS

We are based in the UK and many of our external third-party service providers or partners are based outside the UK and the European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the EEA and typically to the USA.

Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Where we use certain service providers, we may use specific contracts often approved by or similar to those approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Where we use providers based in the US, we may transfer data to them only if they provide similar protection to personal data shared in Europe or the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.

7. DATA SECURITY

We have 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, we limit 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 our instructions and they are subject to a duty of confidentiality.

We have 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.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances, we may anonymise your personal data or only collect anonymised data (as in the case for Reality + and related App Clips and Instant Apps (so that it can not be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

You have the right to:

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.

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.

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 to continue 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 (see below), 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.

Object to processing of 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.

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.

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 a contract with you.

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.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE 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 several requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract processing your data where it is necessary for the performance of a contract to which you are a party (such as our terms and conditions) or to take steps at your request before entering into such a contract.

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.

Sandboxed Apps means smaller versions of a full application that operate using less information about you and your device than a full application when you access them. Typically these will be App Clips (iOS) or Instant Apps (Android).

THIRD PARTIES

THIRD PARTIES

INTERNAL THIRD PARTIES

Other companies in the vTime Group acting as joint controllers or processors and who are based in the UK or the US.

EXTERNAL THIRD PARTIES

Service providers acting as processors based outside the UK or EE, and typically in the US or elsewhere who provide IT and system administration or analytics services used by us are set out below. We also list other social media platforms with whom we may share data for the reasons set out above in the paragraphs entitled, DISCLOSURES OF YOUR PERSONAL DATA

. You should review and familiarise yourself with their individual privacy policies.

1. Amazon Web Services - is used for the storage of data and server infrastructure. Amazon Web Services have no direct access to vTime users’ personal information.
2. Apple - we may share certain Technical Data with Apple to enable single sign-on. Apple’s ability to store and process information collected by Apple about you is restricted by Apple’s Terms of Use and Apple’s Privacy Policy.
3. Facebook - we share certain Technical Data with Facebook in order to enable single sign-on and to verify the effectiveness of our ads on their platform and to enable us to provide you with more relevant ads, so as to provide you with a better experience. Facebook’s ability to store and process information collected by Facebook about you is restricted by Facebook’s Terms of Use and Facebook’s Privacy Policy.
4. Google Analytics - we may share certain Technical Data with Google to enable single sign-on. We use Google’s services to help us analyse the usage of our app in order to create a better user experience and improve our System. Google’s ability to store and process information collected by Google Analytics about your visits to our apps, website and system is restricted by the Google Terms of Use and the Google Privacy Policy.
5. Instagram -we may share certain Technical Data with Instagram in order to verify the effectiveness of our ads on their platform and to enable us to provide you with more relevant ads, so as to provide you with a better experience.
6. Mailchimp - we sometimes use Mailchimp’s services to help us with marketing activities. Mailchimp’s ability to store and process information collected by Mailchimp about you is restricted by the Mailchimp Terms of Use and the Mailchimp Privacy Policy.
7. WhatsApp - if you share information on this platform WhatsApp’s ability to store and process information about you is restricted by WhatsApp’s Terms of Use and WhatApp’s Privacy Policy.
   
8. Unity - Unity’s ability to store and process information collected by Unity about you is restricted by the Unity Terms of Use and the Unity Privacy Policy.
9. Facebook Unity Plugin - Facebook’s ability to store and process information collected by Facebook about you is restricted by the Facebook Terms of Use and the Oculus Privacy Policy.
10. HM Revenue & Customs, regulators and other law enforcement authorities (acting as processors or joint controllers) who require reporting of processing activities in certain circumstances