PRIVACY POLICY

This privacy policy aims to give you information on how Nreal Ltd. (“Nreal”/“We”/ ”Us”/ ”Our”) collects and processes your personal data through your use of Nreal’s website https://www.nreal.ai/ (“our site”), including any data you may provide through our site, by telephone, by email or by using the nreal “contact us” page.

It is important that you read this privacy policy so that you are fully aware of how and why Nreal is using your data. This privacy policy supplements other fair processing notices and privacy policies Nreal might provide and is not intended to override them.

Our site is not intended for children and we do not intentionally collect data relating to children.

WHO WE ARE

We are the data controller of and are responsible for your personal data for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) and related data protection legislation. We are a limited company registered in China under company number 91110108MA01DM1T20 and have our registered office at AVIC Plaza A2, 43 N. 3rd Ring W. Rd, Haidian District, Beijing, China.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at: info@nreal.ai

CHANGES TO THIS PRIVACY POLICY

We may update this privacy notice from time to time. Please review this privacy notice periodically for changes. This privacy notice was last updated on 31st may 2019.

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

THIRD PARTY LINKS

Our site 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 data about you. We may not control these third party websites, plug-ins and applications and Nreal is not responsible for their privacy statements or how they deal with or use your personal data.

When you leave our site, we encourage you to and recommend that you read the privacy notice of every website you visit.

COOKIES

Our site uses cookies to distinguish you from other users of our site. This helps Nreal to provide you with a good experience when you browse our site and also allows Nreal to improve our site. For more information, please see our Cookies Policy.

THE DATA WE GATHER 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 may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

“Contact Data” includes full name and email address.

“Technical Data” includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our site.

“Usage Data” includes information about how you use our site, products and services.
“Marketing and Communications Data” includes your preferences in receiving marketing from Nreal and your communication preferences.

Add App Data.

We may also 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, Nreal may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if Nreal combines or connects Aggregated Data with your Personal Data so that it can directly or indirectly identify you, Nreal treats the combined data as Personal Data which will be used in accordance with this privacy notice.

We do not 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 offenses.

HOW WE COLLECT YOUR PERSONAL DATA

We may use different methods to collect data from and about you including through:
Direct interactions. You may give Nreal your Contact Data, Usage Data and Marketing and Communications Data by filling in forms, using Nreal services or by corresponding with Nreal by post, phone, email or otherwise. This includes Personal Data you provide when you:

apply for our products or services;
complete our contact form on our site; or
sign up for our marketing to be sent to you.

Automated technologies or interactions. As you interact with our site, Nreal may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies, and other similar technologies.

HOW WE USE YOUR PERSONAL DATA

We will only use your Personal Data when the law allows Nreal to.

We have set out below a description of all the ways we may use your Personal Data, and the lawful basis on which Nreal relies on to do so.

Please note that Nreal may process your Personal Data by relying on more than one lawful basis depending on the specific purpose for which Nreal is using your data.

Purpose/Activity	Type of Data	Lawful Basis for Processing
To register you as a new subscriber or customer	Contact	To register you as a new subscriber or customer Contact Performance of a Contract with you
To register you as a new subscriber or customer Contact Performance of a Contract with you	Contact, Usage and Marketing and Communications	Performance of a Contract with you and Necessary for our Legitimate Interests (to keep our records updated and to study how users engage with our products and services). To allow you to access and share content with social networks.
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Contact, Usage Marketing and Communications and Technical	Necessary for our Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or business sale)
To use data analytics to improve our site, products and services, marketing, customer relationships and experiences	Marketing and Communications, Technical and Usage	Marketing and Communications, Technical and Usage
To send you marketing communications	Contact, Usage and Marketing and Communications	Consent

“Legitimate Interest” means the interest of Nreal business in conducting and managing the business to enable Nreal to give you the best service/product and the best and most secure experience. We make sure to consider and balance any potential impact on you (both positive and negative) and your rights before Nreal processes your Personal Data for our Legitimate Interests. You can obtain further information about how Nreal assesses our legitimate interests against any potential impact on you in respect of specific activities by contacting Nreal.

MARKETING AND PROMOTIONAL OFFERS FROM NREAL

We may use your Contact Data, Usage Data and Marketing and Communications Data to promote our products and services which may be relevant for you or which may be of interest to you (we call this marketing).

You will receive marketing communications from us if you have provided us with your details and you have opted-in to receiving that marketing.

You can ask us to stop sending you marketing messages at any time 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 as a result of products or services we provide to you or other transactions.

We will get your express opt-in consent before we share your Personal Data with any third parties for marketing purposes.

CHANGE OF PURPOSE

We will only use your Personal Data for the purposes for which Nreal collected it, unless Nreal reasonably considers that Nreal needs to use it for another reason and that reason is compatible with the original purpose.

If Nreal needs to use your Personal Data for an unrelated purpose, Nreal will notify you and explain the legal basis which allows Nreal to do so.

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

We may have to share your Personal Data with the parties set out below for the purposes set out above.

Our affiliated, parent and subsidiary companies.
Service providers who provide services including:
analytics and search engine providers that assist Nreal in the improvement and optimization of our site. This shall include for the avoidance of doubt, Nreal’s use of Google Analytics or other similar analytics services; and newsletter providers that Nreal may select from time to time.
Professional advisers including lawyers, bankers, accountants auditors and insurers who provide consultancy, legal, insurance and accounting and audit services.
Regulators and other authorities to whom Nreal is required to report in certain circumstances.
Third parties where Nreal is under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply Nreal’s Terms & Conditions and other agreements; or to protect the rights, property, or safety of Nreal, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Third parties to whom Nreal may choose to sell, transfer, or merge parts of the business or assets or allot or sell Nreal shares. Alternatively, Nreal may seek to acquire other businesses or merge with them. If a change in ownership happens to Nreal, then the new owners may use your Personal Data in the same way as set out in this privacy notice.

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 and only permit them to process your Personal Data for specified purposes and in accordance with Nreal’s instructions.

HOW LONG WE KEEP YOUR PERSONAL DATA

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

To determine the appropriate retention period for Personal Data, Nreal considers the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which Nreal processes your Personal Data and whether Nreal can achieve those purposes through other means, and the applicable legal requirements.

HOW WE PROTECT YOUR PERSONAL DATA

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, Nreal 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 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 Nreal is legally required to do so.

YOUR RIGHTS

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

Request access to your Personal Data (commonly known as a “subject access request”).
Request correction of the Personal Data that Nreal holds about you.
Request erasure of your Personal Data.
Object to processing of your Personal Data where Nreal is relying on a legitimate interest.
Request restriction of processing of your Personal Data.
Request the transfer of your Personal Data to you or to a third party.
Withdraw consent at any time where Nreal is relying on consent to process your Personal Data.

EXERCISING YOUR RIGHTS

If you wish to exercise any of the rights set out above, please contact us at: info@nreal.ai

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

We may need to request specific information from you to help Nreal 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 Nreal’s response.

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

Information about our use of cookies

Our site uses cookies to distinguish you from other users of our site. This helps Nreal to provide you with a good experience when you browse our site and allows Nreal to improve our site. By continuing to browse our site, you are agreeing to Nreal’s use of cookies.

A cookie is a small file of letters and numbers that Nreal stores on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our site.
Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our site when they are using it. This helps Nreal to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognize you when you return to our site. This enables us to personalize Nreal content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Social Media cookies. These cookies allow you to share website content with social media platforms (including but not limited to Facebook, Instagram or Twitter). We have limited control over such cookies as they are set by social media platforms themselves.
Targeting cookies. These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

We may make use of Google Analytics, or other analytics services, which may use cookies. Please click here for more information on their privacy policies and here for more information on their terms of service.

Please note that other third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which Nreal has no control. These cookies are likely to be analytical/performance cookies or targeting cookies but when you leave our site, Nreal encourages you and recommends that you read the cookies policy of every site you visit.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.