Privacy Policy

This Website Privacy Policy (this “Policy”) describes how Reality Defender, Inc. and our subsidiaries and affiliated companies (collectively, “Reality Defender”, “we”, or “us”) collect, use, and disclose information about you.

This Privacy Policy applies to information we collect: (a) when you access or use our website and other online services (collectively, the “Website”); (b) when individuals communicate with us about you in a business capacity, such as vendors and professional service providers; (c) when you visit our offices or attend our events; and (d) through any other business interactions you may have with us, such as through our customer support channels or on social media pages.

We provide different, additional notices regarding our privacy practices with respect to the commercial services we provide to contracted customers and the proprietary software related to or associated with those services or the performance thereof.

We may change this Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Policy. We may also provide you with additional notice (for example, by adding a statement to our General Terms of Use or by sending you a notification). We encourage you to review this Policy regularly to stay informed about our information practices and the choices available to you.

The personal information we collect about you depends on how you interact with us or use the Website. We describe below the categories of personal information we collect and the sources of this information.

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information directly from you when you create an account, fill out a form through the Website, or submit or post content, communicate with us via third-party platforms, participate in a contest or promotion, request customer support, or otherwise communicate with us. The types of information about you that we may collect include your name; email address; postal address; phone number; account username; account password; a form of identification; photos, images, videos, audio files; and voice recordings; and any other information you may choose to provide. Other types of personal information may be automatically collected when you access or use the Website. The types of personal information collected may include:

• Device and Usage Information. Certain information about how you access the Website may be captured automatically, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, and browser type. Information about your activity on the Website may also be collected, such as access times, pages viewed, links clicked, and the page you visited before navigating to the Website.
• Audio and Video Recordings and Photos. We capture photographs and video recordings in our physical facilities for security and safety purposes.
• Information Collected by Cookies and Similar Tracking Technologies. The Website (and third parties that perform work for us) use tracking technologies, such as cookies and web beacons, to collect information about your interactions. Cookies are small data files stored on your hard drive or in device memory that help us improve the Website and your experience on it, see which areas and features of the Website are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on the Website and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness.
• Information We Collect from Other Sources. We obtain information from other sources. For example, we may collect information from identity verification services, and data analytics providers. Additionally, if you create or log into your Reality Defender account through a third-party platform (such as Google), we will have access to certain information from Google’s platform, such as your name, birthday, and profile picture, in accordance with the authorization procedures determined by the platform.
• Information We Derive. We have the ability to derive information or draw inferences about you based on collected information. For example, we could make inferences about your approximate location based on your IP address.

We principally use the collected information to administer your account. We also use the collected information for the following purposes:

• To provide, maintain, improve, and develop new products and services, including to debug and repair errors in or on the Website;
• To personalize your experience with us;
• To send you technical notices, security alerts, support messages, and other relationship messages;
• To communicate with you, such as about products, services, and events offered by Reality Defender and others and provide news and information that we think will interest you (see the “Your Choices” section below for information about how to opt out of these communications at any time);
• To monitor and analyze trends, usage, and activities in connection with the Website;
• For legal and compliance purposes, such as to implement internal policies, detect, investigate, and respond to suspected fraud, security incidents, or other activity that is illegal or violates our policies, exercise a legal claim, cooperate with law enforcement investigations, and comply with applicable laws, regulations, legal processes, or governmental requests;
• To create de-identified, anonymized, or aggregated information;
• To enable solely internal uses in a lawful manner that are reasonably aligned with your expectations based on our interactions with you and that are compatible with the context in which the information was provided to us; and
• To carry out any other purpose described to you at the time the information was collected.

We may disclose your personal information as follows or as otherwise described in this Policy:

• We disclose personal information to vendors, service providers, contractors, and consultants that access personal information to perform work for us, such as companies that assist us with web hosting, information technology and software services, mailing services, marketing services, event management services, background check providers, cyber and physical security services, and customer service.
• If you provide a product review or otherwise share content on the Website, we may disclose this information publicly and to other users of the Website.
• If you choose to use integrations we offer on the Website, we may disclose certain information with the integration partners.
• We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
• We may disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Reality Defender, our users, the public, or others.
• We may disclose personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• We may disclose personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Personal information may be disclosed between and among Reality Defender and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
• We may disclose personal information with your consent or at your direction.
• We may also disclose aggregated or de-identified information that cannot reasonably be used to identify you.

We engage others to provide Website analytics services. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Website and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Reality Defender and others to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.

Reality Defender is headquartered in the United States, and we have operations and vendors in the United States and other countries. Therefore, we and those that perform work on our behalf may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We provide adequate protection for the transfer of personal data in accordance with applicable law.

You have certain choices with respect to your personal information, as described below.

• Account Information. You may update and correct certain account information at any time through your profile settings.
• Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of the Website. In addition, you may manage your preference through the Cookie Settings link on the Website itself.
• Do Not Track. We do not respond to do not track signals.
• Communications Preferences. You may opt out of receiving messages or promotional emails from Reality Defender by following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Your Privacy Rights

Certain U.S. states afford consumers rights with respect to their personal information. Companies that are regulated by the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020, (collectively, the “CCPA”) are required to explain some information using definitions and categories set out within the CCPA. If you are a resident of California, this section applies to you.

Collection and Use of Personal Information Under the CCPA

Reality Defender may collect the categories of personal information set forth in the table below.

Sources of Information

We collect the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, when you communicate with us.
• Indirectly from you. For example, from observing your actions on the Website, from information your computer or mobile device transmits when interacting with the Website, email sent to your inbox from us, or interactions with us in social media.
• Third parties. For example, third party partners may give us information about you.

How We Use Personal Information‍

As set forth in the table below, Reality Defender may disclose certain categories of personal information to certain categories of recipients in connection with the “Uses of Information” identified in Section 3.

Other Details About Our Information Practices

We do not “sell” or “share” and have not “sold” or “shared” personal information in the preceding twelve (12) months under the laws applicable to you, and we do not knowingly sell or share personal information about individuals under the age of 16. Nor does Reality Defender use or disclose sensitive personal information for the purpose of inferring characteristics about you.

Data Retention‍

We will not retain your personal information for longer than is reasonably necessary to carry out the applicable, identified purposes. To determine the length of time we retain personal information, we consider numerous factors, including legal and regulatory obligations, whether retention of personal information is needed to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes, and/or enforce agreements.

Your Privacy Rights and Choices

Depending on where you reside, you may have the right to: (a) know more about and access the personal information we collect, use, and disclose about you and to receive your data in a portable format; (b) delete your personal information; (c) correct inaccurate personal information; and (d) object to, or request that we restrict, certain processing.

Exercising Your Rights

To exercise the rights described above, please submit a request to us by emailing us at privacy@realitydefender.com. We will verify your request by asking you to provide information sufficient to confirm your identity, such as your name, email address, and information about your interactions with us. If you would like to use an authorized agent to exercise your rights, we may request evidence that you have provided such agent with power of attorney, or that the agent otherwise has valid signed authority to submit requests on your behalf, and ask that you verify your identity directly with us.

If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you have certain additional rights and protections under the law regarding the processing of your personal data, and this Section 8 applies to you.

Legal Basis for Processing

When we process your personal data, we will do so in reliance on the following lawful bases:

• To perform our responsibilities under a contract (e.g., information that you have requested).
• When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve the Website, conduct data analytics, and communicate with you).
• To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
• When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). Note that when consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.

Data Retention

For details about Reality Defender’s data retention practices, see the Data Retention section above.

Privacy Rights

Subject to certain limitations, you have the following privacy rights:

• Access: You are entitled to ask us if we are processing your information and, if we are, you can request access to your personal information. This enables you to receive a copy of the personal information we hold about you and certain other information about it.
• Correction: You are entitled to request that any incomplete or inaccurate information we hold about you be corrected.
• Erasure: You are entitled to ask us to delete or remove personal data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.
• Restriction: You are entitled to ask us to suspend the processing of certain of your personal information about you, for example if you want us to establish its accuracy or the reason for processing it.‍
• Portability: You may ask us to help you transfer certain of your personal information to another party.
• Objection: Where we are processing your personal data based on legitimate interests (or those of a third party), you may challenge this. However, we may be entitled to continue processing your information in case there are compelling legitimate grounds to do so. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Consent: Where we are processing personal data with consent, you can withdraw your consent.

Exercising Your Rights

To exercise any of the rights described above, please submit a request to us by emailing us at privacy@realitydefender.com.

Questions or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

• For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en
• For individuals in the UK: https://ico.org.uk/global/contact-us/ ‍
• For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

If you have any questions about this Policy, please contact us at privacy@realitydefender.com.