In this privacy policy (“Privacy Policy”), it is described how Reality In Virtual Reality Ltd AB including its affiliates (“Reality In Virtual Reality Ltd”) Processes Personal Data. For more information and/or to exercise rights as a Data Subject, contact information to Reality In Virtual Reality Ltd can be found under Contact Information.
User means any entity, organization, corporation or living natural person that uses the Services and/or interacts with Reality In Virtual Reality Ltd in any way.
Data Processor means anyone who Processes Personal Data on behalf of a Data Controller.
Data Controller means a legal entity, who alone or jointly with others, determines the purposes and means of the Processing of Personal Data.
Data Protection Legislation means the applicable data protection legislation such as Regulation (EU) 2016/679 (General Data Protection Regulation; the “GDPR”) and any other applicable data protection legislation.
EU/EEA means the European Union/European Economic Area.
Personal Data means any information that, directly or indirectly, can identify a natural person.
Processing means any operation or set of operations performed with regard to Personal Data, whether or not performed by automated means, such as collection, recording, organisation, storage, adaptation, alteration, retrieval, gathering, use, combination, blocking, erasure or destruction.
Recipient means a natural or legal person, public authority or another body, to whom Personal Data may be disclosed to by Reality In Virtual Reality Ltd.
Services means any of Reality In Virtual Reality Ltd’ services and/or Simulators as well as communications provided on Reality In Virtual Reality Ltd’ websites and other electronic channels.
This Privacy Policy describes how Reality In Virtual Reality Ltd as a Data Controller Processes User’s Personal Data on a general level. Specific information about further Processing can be found in separate agreements, websites or other documents related to Reality In Virtual Reality Ltd.
Reality In Virtual Reality Ltd may need to Process Personal Data in order to provide the Services to the Users, fulfill legal obligation or for the performance of agreements. If a User chooses not to provide or submit Personal Data in the Services, it may prevent Reality In Virtual Reality Ltd from fulfilling the above mentioned obligations. In some cases, Users may not be able to use and access the Services, such as multiplayer features or training session results of the scenarios provided by Reality In Virtual Reality Ltd.
Reality In Virtual Reality Ltd ensures the confidentiality of Personal Data and has implemented appropriate technical and organizational measures to safeguard Personal Data from unauthorised access, unlawful disclosure, accidental loss, modification, destruction or any other unlawful Processing.
Reality In Virtual Reality Ltd may use approved Data Processors for Processing Personal Data. Reality In Virtual Reality Ltd ensures that Data Processors Process Personal Data under documented instructions of Reality In Virtual Reality Ltd which are in accordance with adequate and required security measures in accordance with Data Protection Legislation.
The Services are not directed or intended for children and Reality In Virtual Reality Ltd does not knowingly collect Personal Data from children under 18 years old in the Services. Reality In Virtual Reality Ltd prohibits submission of Personal Data by children, unless sent under the supervision of their parent or guardian.
Reality In Virtual Reality Ltd will promptly delete Personal Data submitted by children unless legally obligated to retain such data.
Reality In Virtual Reality Ltd requests that any parents to children under the age of 18 that may have submitted Personal Data to make contact at help@rivr.uk.
Reality In Virtual Reality Ltd has taken reasonable steps to ensure that Personal Data it collects is secure and reasonable measures are put in place to protect the confidentiality, security, and integrity of the Personal Data collected from our Users. Personal Data is stored in secure operating environments that are not available to the public and that are only accessible to authorized employees and contractors. Reality In Virtual Reality Ltd also has security measures in place to protect the loss, misuse, and alteration of the information under our control.
Any improper collection or misuse of User Created Content or information provided in the Simulator is a violation of the Terms of Use and should be reported to Reality In Virtual Reality Ltd at help@rivr.uk.
Reality In Virtual Reality Ltd primarily collects from and Processes Personal Data of Users of the Services, such as students of the Simulators provided by Reality In Virtual Reality Ltd. Personal Data may be collected from Users directly, by User’s submission of Personal Data and/or automatically from the use of the Services. Reality In Virtual Reality Ltd may also save electronic communications or otherwise document Reality In Virtual Reality Ltd’ interaction and communication with Users in various electronic channels. Reality In Virtual Reality Ltd also collects non-personal identifiable information, such as anonymous Simulator data and statistical information, derived from the Services, in order to improve the Services.
Reality In Virtual Reality Ltd also collects and Processes Personal Data from prospect customers, agents, legal representatives, corporate representatives, signatories, shareholders, contact persons, board members, job applicants and visitors of Reality In Virtual Reality Ltd’ offices.
Reality In Virtual Reality Ltd may also collect Personal Data from other sources, such as third party sites or platforms, newspapers, blogs, instant messaging services in order to improve and provide the Services as well as a more personalized experience. Reality In Virtual Reality Ltd will in some cases ask for email addresses for sales and marketing purposes.
Reality In Virtual Reality Ltd simulators give the user options to use voice to text services as well as creative writing from prompts. For this service, we use OpenAI api’s, and this data is subject to OpenAIs privacy policy https://openai.com/enterprise-privacy/. In the simulator you will have the option to deny using online AI services.
Upon request of personal data deletion, we will submit a delete request on your behalf to the LLM provider.
The main categories of Personal Data Processed by Reality In Virtual Reality Ltd include:
Identification and contact information such as name, personal identification code/number, internet protocol (IP) address, address, telephone number, email address and country of residence.
Communication information such as complaints/support matters in voice/written form, images and/or audio recordings, emails, messages and other communications such as social media.
Electronic interaction information such as the type of browser that is used, the type of operating system that is used, the IP address or other unique identifier such as a device identifier of any computer(s) or device(s) that are used to access electronic channels.
Reality In Virtual Reality Ltd Processes Personal Data to fulfill obligations in agreements with external parties. This Processing relates to the execution, documentation and administration of agreements entered into by Reality In Virtual Reality Ltd. Examples of purposes for Processing are to verify transactions with business partners, to perform play- and beta tests and to provide the Simulators as part of the Services.
Reality In Virtual Reality Ltd Processes Personal Data in order to fulfill legal obligations imposed by regulators. Examples of purposes for Processing are to identify Users in order to make sure that Reality In Virtual Reality Ltd does not collect Personal Data from children as well as to comply to bookkeeping obligations.
Reality In Virtual Reality Ltd Processes Personal Data in some cases when Users have provided their consent to it and the provided consent can always be withdrawn. An example of purpose for Processing is when subscribing to Reality In Virtual Reality Ltd’ newsletter.
Reality In Virtual Reality Ltd Processes Personal Data based on Reality In Virtual Reality Ltd’ legitimate interest. Reality In Virtual Reality Ltd have concluded this Processing necessary for the interest pursued by Reality In Virtual Reality Ltd, which outweighs the User’s interest of protection of the Personal Data. Examples of purposes for Processing are to improve the Services, to provide personalized offers and direct marketing.
Cookies are used by Reality In Virtual Reality Ltd for different purposes when visiting Reality In Virtual Reality Ltd’ websites. All cookies used are listed in the Cookie Declaration available on Reality In Virtual Reality Ltd’ website.
Based on the legal bases and the purposes for Processing by Reality In Virtual Reality Ltd, Reality In Virtual Reality Ltd may share User’s Personal Data with Recipients to Process Personal Data as a Data Processor. Reality In Virtual Reality Ltd will only share necessary Personal Data for the purposes of the disclosure and never for the Recipients own purposes. Further, Reality In Virtual Reality Ltd will only share Personal Data if the Recipients have ensured an adequate level of protection of the Personal Data in accordance with Data Protection Legislation. Reality In Virtual Reality Ltd may also share anonymous or aggregated information, or other data that is not considered Personal Data with third parties, for example personas on leaderboards or to show trends about the use of Reality In Virtual Reality Ltd’ Services.
Third party agents/contractors/developers.
Support desk
Recipient name: Zendesk
Personal Data: email address and name
Service, data and cloud storage
Recipient name: Google Cloud, Apple, Meta, Pico, Playfab, Unity
Personal Data: Player data, user ID, player progression and settings, logs
Marketing services
Recipient name: Mailchimp and Send Grid
Personal Data: email address and name
Where applicable the Recipient’s Processing of Personal Data will not be covered by this Privacy Policy. In such instances you must review such Recipients’ privacy policies.
Where Personal Data is transferred to a country outside the EU/EEA that is not subject to an adequacy Data Protection Legislation, the transfer will only occur if there are appropriate safeguards in place such as (i) an agreement with the EU Standard Contractual Clauses, code of conducts, certifications or other clauses compliant and in accordance with Data Protection Legislation, or (ii) the country outside EU/EEA has an adequate level of data protection as approved by the EU Commission.
Reality In Virtual Reality Ltd will not retain Personal Data longer than necessary for the purposes for the Processing carried out by Reality In Virtual Reality Ltd unless required by Data Protection Legislation. Reality In Virtual Reality Ltd may need to retain Personal Data in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules. Personal Data is deleted or anonymized by Reality In Virtual Reality Ltd as soon as it no longer serves the purpose it was collected and Processed for.
User’s have the following general rights as Data Subjects regarding the Processing of Personal Data carried out by Reality In Virtual Reality Ltd:
Right to correction meaning the Users can request to correct the Personal Data if the Personal Data is incorrect, incomplete or inadequate.
Right to objection meaning Users can object to the Processing for certain purposes, such as direct marketing.
Right to erasure meaning Users can require the Personal Data to be deleted.
Right to restriction meaning the User can restrict the Processing, for example when the amount of Personal Data necessary for Processing is contested by the User.
Right to information and access meaning the Users can receive information if their Personal Data is Processed and gain access to their Personal Data.
Right to receive a copy of the Personal Data meaning the Users can request to receive their Personal Data that is Processed, provided that the Processing is based on Performande of agreement or consent. The Personal Data will be received in written or commonly used electronic format. If technically feasible, the User may request that the Personal Data is transferred to another Data Controller.
Right to withdraw consent meaning the Users can withdraw their consent to the Processing of Personal Data.
Right to request not to be subject to fully automatic decision-making meaning the Users can request that their Personal Data is not part of Processing for any automatic decision-making, including profiling, if such processing has any significant or legal effects for the Users. If the decision-making is in accordance with Data Protection Legislation and/or the Users have provided their explicit consent, this right is not applicable.
Please note that the above described rights for the Users as Data Subjects may be limited if the Personal Data is necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims
To invoke any of the rights described above or for more information regarding the rights, Users may contact Reality In Virtual Reality Ltd at any time by emailing help@rivr.uk. Reality In Virtual Reality Ltd will process and answer requests without undue delay and in any event within one month of the receipt of the request unless a longer period is required due to the complexity of the request. In this case, the response time can be up to three months in total.
This Privacy Policy applies to all Personal Data collected or provided to Reality In Virtual Reality Ltd. This Privacy Policy is subject to change and Reality In Virtual Reality Ltd may make any necessary changes to this Privacy Policy. Reality In Virtual Reality Ltd will notify Users of material changes by posting providing information about the changes in the Services. Users are encouraged to check back and review this Privacy Policy from time to time so that Users are always aware of what Personal Data is collected, how it is Processed and for which purpose and to whom it is disclosed. All continued use of and access to the Services is subject to this Privacy Policy and will signify Users acceptance of Privacy Policy and any potential changes to it.
For any questions, complaints or comments regarding our Privacy Policy, or to exercise the rights as a Data Subject, please contact Reality In Virtual Reality Ltd at:
Reality In Virtual Reality Ltd
help@rivr.uk
Last Updated Date: 16 May 2024
