Inner Reality Ltd. Privacy Policy

Last modified: [04/24/2023]

Introduction

Inner Reality Ltd., a United Kingdom corporation (“IRL”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes the types of information IRL may collect from you or that you may provide when you use an application, product or service IRL offer (our “App”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information IRL collect:

· On Our App

· When you interact with our advertising and applications on third-party IRL sites and services, if those applications or advertising include links to this policy.

· In email, text, and other electronic messages between you and the App.

It does not apply to information collected by:

· IRL offline or through any other means, including on any other website operated by IRL or any third party (including our affiliates and subsidiaries); or

· Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website (see Third-Party Information Collection).

Our websites and other apps and other third parties may have their own privacy policies, which IRL encourage you to read before providing information on or through them.

Please read this policy carefully to understand our policies and practices regarding your information and how IRL will treat it. If you do not agree with our policies and practices, do not register with, or use this App. By registering with, or using this App, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this App after IRL revise this policy means you accept those changes, so please check the policy periodically for updates.

Information IRL Collect and How IRL Collect It

IRL collect information from and about users of our App:

· Directly from you when you provide it to us.

· Automatically when you use the App.

Information You Provide to Us

When you register with, or use this App, IRL may ask you to provide information by which you may be personally identified, such as name, postal address, email address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”). This information includes:

· Information that you provide by filling in forms in the App. This includes information provided at the time of registering to use the App. IRL may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the App.

· Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.

· Details of transactions carried out through the App.

You may also provide information for publication or display (“Posted”) on public areas of the App or websites accessible through the App (collectively, “User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, IRL cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, IRL cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Automatic Information Collection

When you access, and use the App, it may use technology to automatically collect:

· Usage Details. When you access and use the App, IRL may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App.

· Device Information. IRL may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.

· Stored Information and Files. With your permission, the App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.

IRL also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking). If you do not want us to collect this information, do not use the App.

Information Collection Technologies

The technologies IRL use for automatic information collection may include:

· Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App.

· Web Beacons. Pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit IRL, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

Third-Party Information Collection

When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

· Advertisers, ad networks, and ad servers

· Analytics companies

· Your mobile device manufacturer

· Your mobile service provider

These third parties may use tracking technologies to collect information about you when you use this App. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

IRL do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Inner Reality Platform Information Collection

Inner Reality uses Virtuoso to manage user identities. Virtuoso acts as a “data processor” to Inner Reality under United Kingdom data laws and as a “service provider” under the CCPA (as defined below). For the data that Inner Reality collects, please see Inner Reality’s privacy policy at www.innereality.com

As part of the user account creation and to support certain features within Virtual Asset Tokens (VAT’s) that Inner Reality develops, Inner Reality may collect additional data for a user. For example, the email address may be collected as part of the sign up process so that users can be reached via email to be informed about updates on the current campaign or upcoming future campaigns. That email address may also be shared with a Client (as defined below) the user has signed up through. If shared, the privacy policy of that Client applies with regards to how they use the shared user data.

How IRL Use Your Information

IRL use information that IRL collect about you or that you provide to us, including any personal information, to:

· Provide you with the App and its contents, and any other information, products or services that you request from us.

· Fulfill any other purpose for which you provide it.

· Carry out our obligations and enforce our rights arising from any contracts entered into between you and IRL, including for billing and collection.

· Notify you when App updates are available, and of changes to any products or services IRL offer or provide though it.

The usage information IRL collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to:

· Estimate our audience size and usage patterns.

· Store information about your preferences, allowing us to customize our App according to your individual interests.

· Speed up your searches.

· Recognize you when you use the App.

IRL may use the information IRL collect to display advertisements to our advertisers’ target audiences. Even though IRL do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

IRL may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

In addition, IRL may disclose personal information that IRL collect or you provide:

· To our subsidiaries and affiliates.

· To contractors, service providers, and other third parties IRL use to support our business.

· To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Inner Reality’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information about our App users is among the assets transferred.

· To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website or App, IRL will transmit the contents of that email and your email address to the recipients.

· For any other purpose disclosed by us when you provide the information.

· With your consent.

· To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

· To enforce our rights arising from any contracts entered into between you and us, including the App EULA.

· If IRL believe disclosure is necessary or appropriate to protect the rights, property, or safety of Inner Reality, our customers or others.

Your Choices About Our Collection, Use, and Disclosure of Your Information

IRL strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms IRL provide for you to control certain uses and disclosures of your information.

· Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.

· Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the App may then be inaccessible or not function properly.

· Promotion. If you do not want IRL to use your email address to promote IRL’s own or third parties products or services, you can opt out. You can always opt out by logging into the App and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes.

IRL do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Children’s Privacy

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Data Security

IRL have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where IRL have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. IRL ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although IRL do our best to protect your personal information, IRL cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. IRL are not responsible for circumvention of any privacy settings or security measures IRL provide.

Changes to Our Privacy Policy

IRL may update our privacy policy from time to time. If IRL make material changes to how IRL treat our users’ personal information, IRL will post the new privacy policy on this page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring IRL have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Data Protection Rights

IRL respond to all requests that IRL receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. Rights that you may have, depending on the country in which you live, include:

· Accessing, correcting, updating, or requesting deletion of your information.

· Objecting to processing of your information, asking us to restrict processing of your information, or requesting the portability of your information.

· Withdrawing your consent at any time if IRL have collected and processed your information with your consent. Withdrawing your consent will not affect the lawfulness of any processing that IRL conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.

· Complaining to a data protection authority about our collection and use of your information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Union are available here.

Under European data protection law, the “controller” of your information is Inner Reality Ltd.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to Joss.davidge@innereality.com.

CCPA Compliance

IRL adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA). Any terms defined in the CCPA have the same meaning when used in this notice.

Our App collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our App has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category Examples Collected

A. Identifiers. A real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. YES

B. Personal information

categories listed in the

California Customer Records

statute (Cal. Civ. Code §

1798.80(e)). A name, telephone number, or any financial information. Some personal information included in this category may overlap with other categories. YES

C. Protected classification

characteristics under

California or federal law. Age, sex, gender or gender identity. YES

D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES

E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and NO

sleep, health, or exercise data.

F. Internet or other similar

network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES

G. Geolocation data. Physical location or movements. YES

H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. YES

I. Professional or

employment-related

information. Current or past job history or performance evaluations. NO

J. Non-public education

information (per the Family

Educational Rights and

Privacy Act (20 U.S.C.

Section 1232g, 34 C.F.R.

Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO

K. Inferences drawn from

other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES

Personal information does not include:

· Publicly available information from government records.

· Deidentified or aggregated consumer information.

· Information excluded from the CCPA’s scope, like:

· health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

· personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

IRL obtain the categories of personal information listed above from the following categories of sources:

· Directly from you. For example, from forms you complete or products and services you use.

· Indirectly from you. For example, from observing your actions on the App.

Use of Personal Information

IRL may use or disclose the personal information IRL collect for one or more of the following purposes:

· To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, IRL will use that personal information to respond to your inquiry.

· To provide, support, personalize, and develop our App, products, and services.

· To create, maintain, customize, and secure your account with us.

· To process your requests, purchases, transactions, and payments and prevent transactional fraud.

· To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

· To personalize your App experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our App, third-party sites, and via email or text message (with your consent, where required by law).

· To help maintain the safety, security, and integrity of our App, products and services, databases and other technology assets, and business.

· For testing, research, analysis, and product development, including to develop and improve our App, products, and services.

· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

· As described to you when collecting your personal information or as otherwise set forth in the CCPA.

· To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our App users is among the assets transferred.

IRL will not collect additional categories of personal information or use the personal information IRL collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

IRL may disclose your personal information to a third party for a business purpose. When IRL disclose personal information for a business purpose, IRL enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. IRL share your personal information with the following categories of third parties:

· Service providers.

· Clients: our clients are third parties with whom you have directed us to share your personal information by means of an intentional interaction (“Clients”)

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category H: Sensory data.

IRL disclose your personal information for a business purpose to the following categories of third parties:

· Service providers.

· Clients

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that IRL disclose certain information to you about our collection and use of your personal information over the past 12 months. Once IRL receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), IRL will disclose to you:

· The categories of personal information IRL collected about you.

· The categories of sources for the personal information IRL collected about you.

· Our business or commercial purpose for collecting or selling that personal information.

· The categories of third parties with whom IRL share that personal information.

· The specific pieces of personal information IRL collected about you (also called a data portability request).

· If IRL sold or disclosed your personal informationfor a business purpose, two separate lists disclosing:

ries that each category of recipient purchased; and

· disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that IRL delete any of your personal information that IRL collected from you and retained, subject to certain exceptions. Once IRL receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), IRL will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

IRL may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which IRL collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

· Contact info@innereality.com

· Access the IRL website at www.innereality.com and contact us via the details provided on the “Contact Us” page. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

· Provide sufficient information that allows us to reasonably verify you are the person about whom IRL collected personal information or an authorized representative.

· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

IRL cannot respond to your request or provide you with personal information if IRL cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, IRL do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

IRL will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

IRL endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If IRL require more time (up to 90 days), IRL will inform you of the reason and extension period in writing.

If you have an account with us, IRL will deliver our written response to that account. If you do not have an account with us, IRL will deliver our written response electronically.

Any disclosures IRL provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response IRL provide will also explain the reasons IRL cannot comply with a request, if applicable. For data portability requests, IRL will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

IRL do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If IRL determine that the request warrants a fee, IRL will tell you why IRL made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

IRL will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, IRL will not:

· Deny you goods or services.

· Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

· Provide you a different level or quality of goods or services.

· Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at info@innereality.com