Realms Platform Privacy Notice

This Privacy Notice is designed to help you understand how Realms Today Ltd (“RT,” “we,” “us,”or “our”) collects, uses, processes, and shares your personal information on the Realms Platform (https://realms.today/realms), and to help you understand and exercise your privacy rights.

1. SCOPE AND UPDATES TO THIS PRIVACY NOTICE
2. PERSONAL INFORMATION WE COLLECT
3. HOW WE USE YOUR PERSONAL INFORMATION
4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
5. YOUR PRIVACY CHOICES AND RIGHTS
6. SECURITY OF YOUR INFORMATION
7. INTERNATIONAL DATA TRANSFERS
8. RETENTION OF PERSONAL INFORMATION
9. SUPPLEMENTAL NOTICE FOR UK AND EU RESIDENTS
10. CHILDREN’S INFORMATION
11. OTHER PROVISIONS
12. CONTACT US

1. SCOPE AND UPDATES TO THIS PRIVACY NOTICE

This Privacy Notice applies to personal information processed by us on the Realms Platform (https://realms.today/realms), which to make this Privacy Policy easier to read, will be called the “Services.”

An Important Note regarding Blockchain Technologies: If you participate in our Services relating to the creation and management of a decentralized autonomous organization (“DAO”), smart contracts will be employed that necessarily collect information, such as your cryptocurrency wallet address (which some legal jurisdictions may consider personal information), and that information will be stored on a public blockchain that we do not control. A smart contract is computer code that automatically processes events when certain conditions are met; for example, when a proposal is presented to a member’s DAO and after all needed votes are made by respective DAO member, the smart contract will execute the proposed action if the proposal passed. In these situations, your personal information will be stored on that blockchain through the execution of a smart contract and may not be able to be modified or deleted due to the immutable nature of the blockchain.  

Changes to our Privacy Notice. We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.

2. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

3. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

1. Provide Our Services

We use your information to fulfill our contract with you and provide you with our Services, such as:

• Providing access to certain areas, functionalities, and features of our Services;
• Answering requests for customer or technical support;
• Communicating with you about your account, activities on our Services, and policy changes; and
• Allowing you to register for events.
  

2. Administrative Purposes

We use your information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Services;
• Improving, upgrading, or enhancing our Services;
• Developing new products and services;
• Ensuring internal quality control and safety;

• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;
• Debugging to identify and repair errors with our Services;
• Auditing relating to interactions, transactions, and other compliance activities;
• Sharing personal information with third parties as needed to provide the Services;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

3. Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

4. Other Purposes

We also use your personal information for other purposes as requested by you or as permitted by applicable law.

• With Your Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

• De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about the device from which you access our Services, or other analyses we create.

4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

1. Disclosures to Provide our Services

The categories of third parties with whom we may share your personal information are described below.

• Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, and related services.

• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

• Affiliates. We may share your personal information with our company affiliates.

• Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”

• APIs/SDKs. We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

2. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

3. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

6. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

7. INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

8. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Notice for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.  

9. SUPPLEMENTAL INFORMATION FOR UK AND EU RESIDENTS

We will take all necessary steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy. For any transfers of data outside the EEA or the UK, the data transfer will be under the European Commission’s model contracts for the transfer of personal information to third countries (i.e., the standard contractual clauses) (the “Model Clauses”), or any equivalent contracts issued by the relevant competent authority of the UK.

DATA PROTECTION RIGHTS

• You are entitled to a certain number of legal rights concerning the personal information we may hold about you. These rights can be exercised at any time by contacting us.These rights are not absolute and may be limited by law.
• The following rights apply regarding the collection of your personal information:
  1. Right to Access: you have the right to access your personal information stored with us, how we use it, and who we share it with
  2. Right of Portability:you have the right to receive a copy of all your personal information stored by us in a structured, commonly used and machine-readable format and/or request transfer of the same to a third party, in certain circumstances and with certain exceptions.
  3. Right to Rectification:you have the right to correct any inaccurate personal information.
  4. Right to Erasure:In certain circumstances, you have the right to delete your personal information stored with us. There may be circumstances where you ask us to erase personal information, but we are legally entitled to retain it; in such circumstances, the same shall not be erased.
  5. Right to restrict processing:you have the right to require us to stop processing the personal information we hold about you, other than for storage purposes, in certain circumstances.
  6. Right to Objection:you have the right to object to our processing of your personal information. There may be circumstances where you object to or asks us to restrict the processing of personal information, but we are legally entitled to refuse that request.
  7. Objection to marketing:you can object to marketing at any time by opting out using the unsubscribe/opt-out function displayed in our communications to you.
  8. Withdrawal of consent:Where we rely on consent to process your personal information, you have the right to withdraw this consent at any time In certain circumstances it may be lawful for us to continue processing without consent if we have a legitimate reason (other than consent) for doing so.

REQUESTS AND COMPLAINTS

If you have complaints about how we process your personal information, please contact us at admin@realms.today and we will respond to your request as soon as possible. If you think we have infringed data protection laws, you may file a claim with the data protection supervisory authority in the EEA country of your residence.

10. CHILDREN’S INFORMATION

The Services are not directed to those under the age of 18 (or other age as required by local law), and we do not knowingly collect personal information from children.

12. OTHER PROVISIONS

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

Supervisory Authority. If your personal information is subject to the applicable data protection laws of Brazil or Switzerland, you have the right to lodge a complaint with the competent supervisory authority or attorney general if you believe our processing of your personal information violates applicable law.

• Autoridade Nacionalde Proteçãode Dados (ANPD)
• Swiss Federal Data Protection and Information Commissioner (FDPIC)

13. CONTACT US 

Realms Today Ltd is the controller of the personal information we process under this Privacy Notice.

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at: