Introduction to this Privacy Notice
This Privacy Notice applies to personal information Atlas Reality, Inc ("Atlas Reality") collects and uses about individuals who visit our website (https://www.atlasreality.com/) ("Website"), use our mobile applications ("Apps"), create an account with us, register for our events, join our marketing lists, and/or buy goods or services from us (collectively, "Services"). It describes how we collect, use, and protect personal information, and your rights in respect of your personal information.
About Atlas Reality
Atlas Reality is a mobile games technology company. If you have a question or concern about our use of your personal information, please email: privacy@atlasreality.com.
Quick links
- Collection of information
- Use of information
- Disclosure of information
- International transfers
- Cookies
- Your rights
- Data retention
- Children
- Updates
- Additional information for EEA/UK
- Additional information for California
- Additional information for Brazil
- Additional information for Japan
- Additional information for South Korea
Collection of information
We collect personal information about you in the following ways:
1. Information you provide voluntarily
You may choose to provide us with personal information when you use our Website or Services. The types of personal information you may provide voluntarily include:
Identity data. This is personal information you provide to create or maintain an account with Atlas Reality, such as your name, email, phone number, billing address and proof of identity or age. Atlas Reality may receive this information from you if you choose to complete and submit an online registration form to register your account with Atlas. If you choose to sign up or log in to our Services using a third party account such as Apple, Google or Meta, using their sign-in features, those third parties provide us with information such as your email address, user ID and public profile.
Location data. In order to use some of our Services, we will ask you to enable location services for our Apps within your device settings. Where you enable location services for our Apps, we collect approximate location information from your device. Depending on your region, you may also have the option to turn on precise location through your device's location services.
Profile data. Some parts of the Services may enable you to build a public profile in connection with your Account ("Public Profile"). Your Public Profile will include your username and profile picture.
User content. The Services may offer a feature that allows users to post, record, share content or media, including without limitation photos, videos, recordings, text, literary work, computer and/or programming code ("Content"). Users may share Content via email, by accessing their personal email accounts. Users may also share screenshots or recordings with our customer support team via our customer service chat function. Please note that the content you choose to post in the Community Feed - together with your public profile name, profile image, view counts, like counts and tip totals – may be visible to all other users of the Services and, where you share an external link to a post, to anyone who accesses that link outside the Services. Atlas Reality cannot control how third parties may use or further disclose such publicly viewable information.
Communications data. This is personal information relating to any correspondence you send us (for example, questions you send about our Services), via our online form, customer support chat service, or if you send us an email. We may also communicate with you via SMS if you choose to receive text messages from us, and we may send you push notifications if you have authorised these in your device settings. We will collect information such as the communication type, content, subject, sender, recipient and date.
Payment data. This is personal information you provide to purchase Services, such as an online game, and information relating to any transactions you make through the Services. Third party payment providers will collect information about the Services purchased, the payment amount, payment method, date of purchase and your purchase history on our behalf.
Preference data. This is personal information relating to any settings you select on our Website or in connection with our Services, such as language or display settings.
2. Information we collect automatically
When you visit our Website or use our Services, we may collect some personal information automatically. The types of personal information we collect automatically may include:
Device and usage data. This is personal information relating to visits to our Website and our Services from your computer or other device (e.g. mobile devices), such as your IP address, approximate geographical location (e.g. country / city-level), browser type, internet service provider, and resources viewed (e.g. Website pages), operating system, length of visit and referring website addresses.
We may collect this personal information using cookies (and similar technologies). For more information about our cookies (and similar technologies), please see our Cookie Statement. If you wish to change your cookie preferences, you can access our cookie management tool.
3. Information we collect from third party sources
In some cases, we may collect personal information about you from third party sources, as set out below.
Third party platforms. When you choose to sign up for or log in to the Services using sign-in features provided by third party platforms, including Google, Meta and Apple. They provide us with information including authentication data, including details about your device, time of login and security tokens. They also share certain account information with us including your email address, user ID, app permissions, and basic and public profile data, depending on permissions granted by the user. These providers also share certain usage information with us, including login attempts, session durations and any suspicious behaviour detected.
Advertising, measurement and other partners. Advertisers, measurement and other partners share information with us about you and the actions you have taken outside of the Services, such as your activities on other websites and apps, including the products or services you purchased, information about how you interact with their services. These partners also share information with us, such as mobile identifiers for advertising, advertising impressions and clicks and cookie identifiers, which we use to help match you and your actions outside of the Services with your account.
Payment and transaction fulfilment providers. We receive information about you from payment and transaction fulfilment providers, such as payment confirmation details, billing information, transaction details and subscription information.
Use of information
We use the personal information we collect about you for the following reasons:
To provide the Website and the Services to you. We will use your personal information to provide our Website and the Services to you, including to maintain any account you have with us and process any orders you place. The types of information we use for this purpose are identity data and payments data, as described above.
To generate analytics. We will use your personal information to generate analytics for the purpose of better understanding how our visitors and customers use our Website and the Services, so that we may continually improve our offering. The types of information we use for this purpose are identity data and device data, as described above. Examples of such analytics include, without limitation, total and unique impressions of Community-Feed posts, "TrueView" watch-time metrics, tip counts associated with a post, and aggregate engagement rates.
To send Service or support-related communications. We will use your personal information to send Service or support-related communications to you (for example, to respond to a "Contact Us" or administrative request (for example, to change your password, to confirm orders you have placed with us, to update you about the status of a delivery or about updating your account details), as well as to respond to any inquiries you raise. The types of information we use for this purpose are identity data, payments data, preference data and device data, as described above.
To deliver advertising and send marketing. We may use your personal information to send you marketing communications (including news, promotions, offers, push notifications and market surveys) and provide you with online advertising in accordance with any preferences you have expressed (on our Website and on third party websites). The types of information we use for this purpose are identity data, payment data, preference data and device data, as described above. Online advertising technologies use cookies (and similar technologies) to work. If you wish to change your cookie preferences, you can access our cookie management tool.
To maintain security. We use your personal information to maintain the security of our Website and Services (for example, to detect and prevent fraudulent behaviour, violations of our terms of service, or similar). The types of information we use for this purpose are identity data and device data, as described above.
To comply with legal requirements. We will use your personal information to comply with the laws and regulations to which we are subject (for example, legal requirements to report to tax authorities, disclose information to law enforcement authorities, or similar). The types of information we use for this purpose are identity data and device data, as described above.
Disclosure of information
Where permitted by applicable law, we may disclose your personal information to the following categories of recipients:
Our service providers. We may share your personal information with service providers who provide services related to the delivery of the Website and the Services (for example, we engage a security provider, a hosting provider, a survey provider, payment providers, insurers and professional advisers). These service providers may include content-moderation partners who review or algorithmically evaluate users' public post, comments, profile data, and uploaded media for compliance with our policies and applicable law.
Our advertisers. We provide advertisers with aggregate information about the performance of their ads and other content on our Services in order to help them measure their effectiveness. For example, we share information about the ads our users engaged with, and when. We create this aggregate information using information you provide, and automatically collected information, as set out above. We don't share information with these advertisers and their vendors that by itself can be used to identify you.
Our integrated partners. When you choose to use certain features on the Services, such as the completion of surveys, booking travel and watching ads, which are integrated with a third-party partners' products or services, they may receive information about you and your activity.
Competent authorities. We may use and disclose your personal information where we believe it is necessary to exercise, establish or defend legal claims, to protect the vital interests of any person, or to comply with an order or request from any competent court, regulator, law enforcement agency or government authority.
Corporate transactions. We may disclose your personal information to potential buyer (and its agents and advisers) in connection with any proposed purchase of any part of our business. We will inform the buyer to use your personal information only for the purposes set out in this Privacy Notice.
Other third parties. We will only transfer your personal information to other third parties with your consent or where we are required or permitted by law to do so.
International transfers
Atlas Reality is located in the United States, but our service providers operate in various countries around the world. For these reasons, when you visit our Website or use our Services, your personal information may be transferred to countries other than the country in which you reside. Atlas Reality will take all necessary measures to ensure that your personal information is protected in accordance with this Privacy Notice and that any such transfers are lawful.
Some countries may have specific requirements that apply when we transfer personal information internationally. Where this is the case, the requirements that apply and measures we take to comply with those requirements (where applicable) are described further under the relevant "Additional information for individuals in…" heading below.
Cookies
We use cookies to provide our Website and Services. For more information, please see our Cookie Statement. If you wish to change your cookie preferences, you can access our cookie management tool.
Your rights
Depending on where you live, you may have certain rights with respect to your information. For example, under the laws of certain countries and (as they become effective on various dates) of several US states—such as California, Colorado, Oregon, and others—you may have the following rights:
- to receive general information about our processing activities,
- to confirm that we are processing personal information about you,
- to request access to, correction of, deletion of, or portability of personal information that we process about you,
- to request that we restrict processing, or to object to our processing, of personal information about you,
- to opt-out of marketing communications that we may send you (even if you previously consented to receive these) – for example, by clicking on the unsubscribe link in any marketing emails we send,
- to opt-out of the "sale" or "share" of your data (or opt out of the use of your personal information for targeted advertising)
- to not be subject to wholly automated decisions if these have legal effects on you or similarly significantly affect you,
- if our processing is based on your consent, to withdraw your consent to our processing (although this will not affect the lawfulness of our processing prior to your withdrawal), and
- to not be discriminated against for exercising of your data protection rights.
Please see the bottom of this Privacy Notice which contains additional information for individuals located in certain regions (including California residents) which may set out additional rights to which you are entitled, depending on where you live.
Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information that you request to be deleted in order to continue to provide our Services to you.
We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and certain account information. Applicable law may also permit you to designate an authorized third party to submit certain requests on your behalf. In order for an authorized third party to be verified, you must provide the authorized third party with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent's request.
Please contact us using the details provided in this Privacy Notice if you wish to exercise any of these rights. We will fulfil any such requests in accordance with applicable laws.
In addition, you also have the right to complain to your local data protection authority about our use of your personal information. However, while you are not required to do so, we ask that you contact us first to give us the opportunity to address your concerns directly before speaking with your data protection authority.
Sale/share/targeted advertising opt out rights
Under the laws in certain U.S. jurisdictions—such as California, Colorado, Connecticut Oregon, and others (as described above)—you also have the right to opt out of our processing or sharing of your information for online targeted advertising purposes. Note that certain state laws also allow you to opt out of the "sale" of your information to third parties in exchange for valuable consideration. A helpful compendium of U.S. state privacy laws is maintained by the International Association of Privacy Professionals, at https://iapp.org/resources/article/us-state-privacy-legislation-tracker/. We in turn may use analytics and online advertising tools that result in the disclosure of your information to our third-party partners and that are subject to this opt out right.
If you would like to opt out of our online disclosure, such as through tracking technologies, of your personal information for purposes that could be considered "sales" for those third parties' own commercial purposes, or "sharing" for purposes of targeted advertising, please click on the "Your Privacy Choices" on the footer of the Website or in the settings of the App. Please note that you will need to exercise your choice on each browser and each device you use to access the Services. Also, if you have certain settings selected in your browser (including pop-up blockers) you may need to re-configure those settings to adjust your settings.
You can also submit a request to opt out of our offline disclosures of information (i.e., those not based on cookie/pixel or SDK technologies) that are subject to applicable opt out rights by emailing us at privacy@atlasreality.com.
Please note that we do not knowingly sell the personal information of minors under 16 years of age.
Additionally, please note that if you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.
Data retention
We store the personal information we collect for as long as is necessary for the purpose for which it was collected (for example, as long as is necessary to provide you with the Website or the Services) or as otherwise necessary to comply with applicable legal requirements.
When we have no ongoing need to use your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information is stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.
Children
Neither our Website nor our Services are intended for or advertised to children under 16 (or, if applicable laws specify an older age for individuals to be able to use our Website or Services, the age specified by those laws). Our Services require the user to be aged 16 or older (depending on applicable laws) in order to use them. In such circumstances, we may ask users to provide additional information to confirm their age. We do not knowingly or intentionally collect information about children under 16.
If you believe that we have collected information about a child under 16, please contact us using the details provided above so that we may delete the information.
Updates
We may update this Privacy Notice from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with law.
To see when this Privacy Notice was last updated, please see the "Last Updated" section at the outset of this Privacy Notice.
Additional information for individuals in the EEA/UK and Switzerland
If you are in the European Economic Area ("EEA") or UK, then please note the following additional information:
1. Data controller
The data controller of your personal information is Atlas Reality. You can contact Atlas Reality using the details provided above.
2. EEA/UK representatives
Atlas Reality's representative in the EEA is AtlasReality@lionheartsquared.eu.
Atlas Reality's representative in the UK is AtlasReality@lionheartsquared.co.uk.
3. EEA/UK legal basis
We use your personal information only as permitted by law. Our legal bases for processing your personal information described in this Privacy Notice are described in the table below.
| Processing purpose | Legal basis |
|---|---|
| To enable us to administer, operate, and provide the Website and Services to you including to create accounts and to provide you with troubleshooting. | Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for an account to use the Services. |
| To enable us to generate analytics for the purpose of better understanding how our visitors and customers use our Website and the Services, so that we may continually improve our offering. | The processing is necessary for our legitimate interests, namely, to identify and resolve issues with the Website and Services and to improve the Website and Services. |
| To enable us to share your information with third parties whose platforms or services are integrated with the Services, such as facilitating your account creation or log in to the Services using sign-in features provided by third party platforms. | The processing is necessary for our legitimate interests, namely, to provide you with a seamless experience, enable third parties to authenticate users, and optimise your user experience. |
| To enable you to use certain features that are integrated with the Services, such as the completion of surveys, booking travel and watching ads, we will share your data with third party partners. | We ask for your consent before we share your information in these instances. You'll always be able to revoke your consent through your device permissions or in-app settings. |
| To communicate with you, including to notify you about changes to the Services, provide customer support to you and send you other service related messages. | The processing is necessary for the performance of a contract with you. |
| To send you marketing communications (including news, promotions, offers, push notifications and market surveys) and provide you with online advertising in accordance with any preferences you have expressed (on our Website and on third party websites). | The processing is necessary for our legitimate interests, namely to promote new developments and features of our Services. We will obtain your consent to send you messages where required by law. |
| To maintain the security of our Website and Services (for example, to detect and prevent fraudulent behaviour, violations of our terms of service, or similar). | The processing is necessary for our legitimate interests, namely, to ensure that the Services are safe and secure. |
| To comply with legal obligations, including where necessary to assist in investigations conducted by any governmental and/or regulatory authority. | This processing is necessary in order to comply with our legal obligations. |
4. International transfers
If Atlas Reality transfers your personal information to a country outside of the EEA (for EEA residents) or the UK (for UK residents), it will ensure that any such transfers are compliant with EU and UK data protection law, as applicable.
In practice, this means that Atlas Reality will only transfer your personal information to a non-EEA or non-UK recipient where: (i) the recipient is located in a country that the European Commission has decided is adequate to receive personal information from the EEA or the UK Secretary of State has decided is adequate to receive personal information from the UK (as applicable); (ii) the recipient has signed appropriate contractual terms with Atlas Reality that incorporate the European Commission's Standard Contractual Clauses or the UK Information Commissioner's International Data Transfer Agreement or International Data Transfer Addendum (as applicable); or (iii) a data transfer derogation applies (for example, where you have consented to the transfer of your personal information).
If you have further questions about our international data transfers and the specific measures we use in any case, please contact us for further information.
Additional information for California residents
1. California Shine the Light Disclosure
California Civil Code Section 1798.83 permits California residents to request information regarding sale of Personal Information to third parties for their direct marketing purposes. We do not engage in such sales.
2. Deletion of Content from California Residents
If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. If you wish to remove such content or Personal Information and you specify which content or Personal Information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
3. California Privacy Rights – CCPA Privacy Notice
Last updated: November 7, 2024
Atlas Reality provides this notice (the "CCPA Privacy Notice") to supplement the information contained in our Privacy Policy. This CCPA Privacy Notice sets forth our privacy practices as required by the California Consumer Privacy Act and California Privacy Rights Act and related regulations (together the "CCPA").
The CCPA Privacy Notice applies only to individuals residing in the State of California who are considered "Consumers" under the CCPA and from whom we collect "Personal Information" as described in the CCPA ("California Consumers"). If you are not a California Consumer (or a resident of California), this does not apply to you and you should not rely on it.
In the below tables and sections, we describe (as required by the CCPA):
- Our Collection and Use of Personal Information – the types of Personal Information (which the CCPA defines broadly) that we collect, the types of sources we collect it from, and generally how we use it.
- Our Business Purposes – our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same.
- Our Sharing or Sale of Personal Information – the types of recipients to whom we share or sell Personal Information.
- Your California Privacy Rights and Choices – what rights California Consumers have under the CCPA with respect to their Personal Information.
Information We Collect
We may collect Personal Information from you in a variety of different situations, including, but not limited to on our website, your mobile device, through email, and in physical locations (such as industry conferences or events).
More specifically, Atlas Reality collects the following categories of Personal Information from and about its California Consumers, which will depend on the particular Business Purpose for which we collect it:
| Categories of information | Purpose of use | Categories of other parties to whom we disclose |
|---|---|---|
| Identifiers such as name, address, email address, telephone number, IP address and device IDs | Provide and operate the Services; Personalize your experience; Provide seamless experience across platforms and devices; Protect our users, Services and properties; Send you marketing and advertising; Market and advertise for third parties; Compliance and risk management | Affiliates and subsidiaries; Vendors and service providers; Ad networks and advertising partners; Entities for legal and security purposes; Entities for sales or transfer of business or assets; Others with your consent |
| Commercial information such as information about your transactions with us | Provide and operate the Services; Personalize your experience; Provide seamless experience across platforms and devices; Protect our users, Services and properties; Send you marketing and advertising; Market and advertise for third parties; Compliance and risk management | Affiliates and subsidiaries; Vendors and service providers; Ad networks and advertising partners; Entities for legal and security purposes; Entities for sales or transfer of business or assets; Others with your consent |
| Financial information such as credit card information stored by our payment processors | Provide and operate the Services; Personalize your experience; Provide seamless experience across platforms and devices; Protect our users, Services and properties; Compliance and risk management | Service providers for payment processing purposes; Entities for legal and security purposes |
| Internet network and device activity data such as device hardware, software, and browsing information | All the same purposes for which we may use Identifiers (see above) | Affiliates and subsidiaries; Vendors and service providers; Ad networks and advertising partners; Entities for legal and security purposes; Entities for sales or transfer of business or assets; Others with your consent |
| General geolocation information such as your approximate location based on IP address | All the same purposes for which we may use Identifiers (see above) | Affiliates and subsidiaries; Vendors and service providers; Ad networks and advertising partners; Entities for legal and security purposes; Entities for sales or transfer of business or assets; Others with your consent |
| Precise geolocation information when you voluntarily choose to participate in location-based services | Provide and operate the Services; Personalize your experience; Provide seamless experience across platforms and devices; Protect our users, Services and properties; Compliance and risk management | Service providers to provide location-based services; Entities for legal and security purposes |
| Audio or visual information such as profile photos and content you post | Provide and operate the Services; Personalize your experience; Provide seamless experience across platforms and devices; Protect our users, Services and properties; Build and manage business-to-business relationships; Compliance and risk management | Affiliates and subsidiaries; Vendors and service providers; Entities for legal and security purposes; Others with your consent |
| Other information any other information you provide to us | Purposes of use will depend on the additional information you provide | Disclosure will depend on the additional information you provide |
Personal Information does not include deidentified or aggregated consumer information.
Atlas Reality obtains the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, from account sign-ups, forms you complete, or products and Services you purchase.
- Indirectly from you. For example, from observing your actions on our website or from information your devices transmit when interacting with our mobile applications, among other things.
- Third parties such as business partners and, if you choose to connect or sign in through a Third Party Account, certain Third Party Account providers (e.g., Instagram, Twitter, and/or Facebook).
How We Use Personal Information/Business Purposes
Additional information on how we may use or disclose the Personal Information we collect from you or about you to do one or more of the following:
- To fulfill or meet the purpose for which you provided the information.
- To contact you and to inform you about products, Services, promotions, special offers, and/or events that may interest you.
- To inform you about products and Services you have purchased from us.
- To provide, support, personalize, and develop our website, 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 experience on the Services and to deliver content and product and service offerings relevant to your interests.
- To help maintain the safety, security, and integrity of our Site, products and Services, databases and other technology assets, and business.
- For research, analysis, and business development, including to develop and improve our website, 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 or subsequently agreed to by you.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Atlas Reality assets.
How We Sell/Share Personal Information
We disclose, sell or share your Personal Information with the following categories of third parties:
- Service providers
- Third parties with whom you direct us to share your personal information
- We may disclose your personal information to third parties for purposes of analytics and advertising.
In the preceding twelve (12) months, Atlas Reality has disclosed the following categories of personal information for a business purpose:
- Identifiers.
- Commercial information.
- Internet or other similar network activity.
- Geolocation data.
Your Consumer Rights and Choices
Without being discriminated against for exercising these rights, the CCPA provides California Consumers with specific rights regarding their Personal Information.
Right to Opt-out of the sale or sharing of your personal information: You have the right to opt out of Atlas Reality's sale/sharing of your personal information for purposes of online analytics and advertising by clicking the "Your Privacy Choices" link in the footer of our site or in the settings of our app.
Right to correct your personal information: California residents have the right to request that we correct inaccuracies about your Personal Information that we collect, use, or sell.
Access to Specific Information and Data Portability Rights: You have the right to request that Atlas Reality disclose certain information to you about our collection and use of your Personal Information over the past 12 months.
Deletion Request Rights: You have the right to request that Atlas Reality delete any of your Personal Information that we collected from you and retained, subject to certain exceptions.
Exercising Your Rights
To exercise these rights, you may use the tools that we make available on the Services or you may submit your request by sending an email to: privacy@atlasreality.com.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing.
Contact Information
If you have any questions or comments about this CCPA Privacy Notice, please email us at privacy@atlasreality.com.
Additional information for individuals in Brazil
1. Atlas Reality DPO
If you have a question or concern about our use of your personal information, you can email Atlas Reality's DPO: privacy@atlasreality.com.
2. Data controller
The data controller of your personal information is Atlas Reality. You can contact Atlas Reality using the details provided above.
3. International transfers
Within the purposes explained on sections "Use of information" and "Disclosure of information", it may be necessary to transfer some of the personal information processed to service providers or partners located abroad, including cloud service providers. In this case, we will take appropriate measures to ensure adequate protection of your personal information in compliance with the requirements of the Brazilian General Data Protection Law (Law No. 13,709/2018) and other applicable data protection legislation, including entering into data transfer agreements with third parties of your personal information, where necessary.
Additional information for individuals in Japan
1. Disclosure of information
In addition to the circumstances illustrated in the Privacy Notice, we may disclose your personal information also in the following circumstances:
To competent authorities: We may use and disclose your personal information where we believe it is necessary to protect life, body or property of any person and it is difficult to obtain your prior consent, or that it is necessary to comply with an order or request from any competent court, regulator, law enforcement agency or government authority.
2. International transfers
If Atlas Reality transfers your personal information to a country outside of Japan, it will ensure that any such transfers are compliant with Japan data protection law.
In practice, this means that Atlas Reality will only transfer your personal information to a non-Japanese recipient where (i) the recipient is located in a country that receives adequate decision from the Personal Information Protection Commission of Japan (ii) Atlas Reality obtains the prior consent on such international transfer while providing necessary information specified under the APPI to the relevant data subjects or (iii) Atlas Reality assures the recipient to comply with the obligations specified under the Act on the Protection of Personal Information (APPI).
Additional information for individuals in South Korea
For residents of South Korea, the provisions of this section apply and take precedence over the Privacy Notice.
1. Data controller
The data controller of your personal information is "Atlas Reality".
2. Purposes of Collection and Use of Personal Information
We collect and use your personal information for the purposes stated in "Use of information" section above.
3. Items of Your Personal Information to Be Processed
Subject to obtaining your consent, we collect and use the items of your personal data stated in the "Collection of information" section above.
Information collected with consent
| Categories of personal information | Purpose of collection and use | Legal Basis |
|---|---|---|
| Identity data, Profile data, Preference data | To enable you to use certain features that are integrated with the Services, such as the completion of surveys, booking travel and watching ads, we will share your data with third party partners. | We ask for your consent before we share your information in these instances. You'll always be able to revoke your consent through your device permissions or in-app settings. |
| Identity data, Profile data, Preference data, User content, Communications data, Device and usage data, Information from advertising measurements and other partners | To send you marketing communications (including news, promotions, offers, push notifications and market surveys) and provide you with online advertising. | We will obtain your consent to send you messages where required by law. |
Information collected without consent
| Categories of personal information | Purpose of collection and use | Legal Basis |
|---|---|---|
| Identity data, Location data, Profile data, User content, Payment data, Preference data, Device and usage data, Information from third party platforms, Personal information from Payment and transaction fulfilment providers | To enable us to administer, operate, and provide the Website and Services to you including to create accounts and to provide you with troubleshooting. | Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for an account to use the Services. |
| Preference data, Device and usage data, Information from third party platforms | To enable us to generate analytics for the purpose of better understanding how our visitors and customers use our Website and the Services. | The processing is necessary for our justifiable interests, namely, to identify and resolve issues with the Website and Services and to improve the Website and Services. |
| Identity data, Device and usage data, Information from third party platforms | To enable us to share your information with third parties whose platforms or services are integrated with the Services. | The processing is necessary for our justifiable interests, namely, to provide you with a seamless experience, enable third parties to authenticate users, and optimise your user experience. |
| Identity data, Communications data | To communicate with you, including to notify you about changes to the Services, provide customer support to you and send you other service related messages. | The processing is necessary for the performance of a contract with you. |
| Identity data, Location data, User content, Communications data, Payment data, Device and usage data, Information from third party platforms, Payment and transaction fulfilment providers | To maintain the security of our Website and Services. | The processing is necessary for our justifiable interests, namely, to ensure that the Services are safe and secure. |
| Identity data, Location data, Profile data, User content, Communications data, Payment data, Preference data, Device and usage data, Information from third party platforms, Information from advertising, measurement and other partners, Information from payment and transaction fulfilment providers | To comply with legal obligations, including where necessary to assist in investigations conducted by any governmental and/or regulatory authority. | This processing is necessary in order to comply with our legal obligations. |
4. Provision of Your Personal Information to Third Parties
| Categories of recipient | Recipient's purposes |
|---|---|
| Service providers | We may share your personal information with service providers who provide services related to the delivery of the Website and the Services. |
| Advertisers | We provide advertisers with aggregate information about the performance of their ads and other content on our Services. |
| Our integrated partners | When you choose to use certain features on the Services, they may receive information about you and your activity. |
| Competent authorities | We may use and disclose your personal information where we believe it is necessary to exercise, establish or defend legal claims. |
| Corporate transactions | We may disclose your personal information to potential buyer in connection with any proposed purchase of any part of our business. |
| Other third parties | We will only transfer your personal information to other third parties with your consent or where required by law. |
5. Overseas Transfer of Personal Data
(1) Cross-border Collection of Personal Information
We collect and use your personal information overseas as follows:
- Country where personal information is directly collected and used: United States
(2) Cross-border Transfer of Personal Information
We transfer your personal information to countries other than the country in which you reside. Atlas Reality will take all necessary measures to ensure that your personal information is protected in accordance with this Privacy Notice and that any such transfers are lawful.
You may refuse to consent to the overseas transfer of personal information by contacting us using the details provide below. However, if you refuse, you will not be able to continue to use our services and products.
6. Access to and Exercise of Rights on Personal Data
(1) You or your legal representative may exercise the following rights related to personal information protection against us at any time:
- To request for access to your personal information;
- To request for correction of your personal information, if it is inaccurate;
- To request for deletion of your personal information; or
- To request for suspension of processing of your personal information.
(2) The exercise of the rights can be made by e-mail to the following department:
| Department | Legal Department |
|---|---|
| legal@atlasreality.com |
7. Measures to Secure Safety of Personal Information
We have established reasonable procedures to ensure that all personal information collected from you are kept secure and protected:
- (1) Administrative measures: Establishment/implementation of internal data management plans; and operation of employee training programs on a regular basis, etc.
- (2) Technical measures: Management of access rights to any personal information processing system, etc.; implementation of measures to prevent falsification and alteration of access records; installation of the access control system; encryption of unique identification information, etc.; and installation and update of all security programs.
- (3) Physical measures: Control of all accesses to the computer rooms, data storage rooms, etc.
8. Additional Use and Provision of Personal Information
In accordance with Articles 15(3) and 17(4) of the Korean Personal Information Protection Act, we may use or provide any personal information for any purpose other than the purposes stated above even without obtaining the data subject's consent. Before deciding to make such additional data use or provision, we take into consideration the following matters:
- Whether the purpose behind the additional information use or provision is related to the original collection purpose;
- Whether the additional information use or provision is foreseeable in light of the circumstance surrounding the collection of the personal information or the processing practices;
- Whether the additional information use or provision does not unfairly infringe upon the interests of the data subject; and
- Whether the measures required to ensure the safety of the personal information, such as pseudonymization or encryption, have been taken.