Privacy Policy

Effective as of November 3, 2021.

This Privacy Policy describes the privacy practices of REAL.app, Inc. (“REAL”, “we”, “us”, or “our”) and how we handle personal information that we collect through our digital properties that link to this Privacy Policy, including the https://stim.io website (the “Site”), the REAL Social mobile application (the “App”), our REAL Coin and Creator Coin services, whether accessed through the App or our other services (the “Coin Properties”) and any other website or mobile application that we own or control and which posts or links to this Privacy Policy (collectively, the “Service”), and the rights and choices available to individuals with respect to their information.

Table of Contents

Personal Information We Collect

How We Use Your Personal Information

How We Share your Personal Information

Your Choices

Other Sites and Services

Security

International Data Transfer

Children

Changes to this Privacy Policy

How to Contact Us

Your California Privacy Rights

Personal Information We Collect

Information you provide to us through the App. Personal information you provide to us through the App includes:

• Personal contact information, such as your first and last name, email address, and phone number
• User-generated content, such as profile pictures, photos, images, music, videos, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the App, as well as associated metadata.  Metadata includes information on how, when, where, and by whom a piece of content was collected and how that content has been formatted or edited.  Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, or other similar data.
• Profile data, such as the username and password that you may set to establish an account with us, date of birth, photograph, biographical details, and any other information that you add to your account profile
• Communications that we exchange with you, including when you contact us with questions or feedback through the App
• Demographic information, such as your city, state, country of residence, postal code, and age
• Usage information, such as information about how you use the App and interact with us, including information associated with any content you submit to us and information you provide when you use any interactive features of the App
• Marketing data, such as your preferences for receiving our marketing communications and details about how you engage with our communications
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection

Information you provide to us if you use Coin Properties in the App. Personal information you provide to us if you use Coin Properties in the App includes:

• Government-issued identification numbers, such as national identification number (e.g. Social Security Numbers, tax identification number, passport number), state or local identification number (e.g. driver’s license or state ID number), and an image of the relevant identification card
• Payment information needed to complete transactions, such as your financial account numbers or payment card information
• Transaction information, such as information about payments to and from you and other details of transactions through the Coin Properties

Information you provide to us through the Site. Personal information you provide to us through the Site includes:

• Personal contact information, such as your first and last name, email address, and phone number
• Profile data, such as the username and password that you may set to establish an account with us, date of birth, photograph, biographical details, and any other information that you add to your account profile
• Communications that we exchange with you, including when you contact us with questions or feedback through the App

Third-party sources.  We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources
• Data providers, such as information services and data licensors that provide demographic and other information
• Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs
• Marketing partners, such as joint marketing partners and event co-sponsors

If you choose to login to the Service via a third-party platform or social media network, or otherwise connect your account on the third-party platform or network to your account through the Service, we may collect information from that platform or network. For example, this information may include your email address and profile picture.

Automatic data collection.  We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications, and other online services, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state, or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our marketing emails or clicked links within them.
• Location data when you authorize our mobile application to access your device’s location.

Cookies and similar technologies. Like many online services, we use the following technologies:

• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating analytics and online advertising.
• Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked.

Data about others. Users of the Service may have the opportunity to refer friends or other contacts to us and share their contact information with us.  Please do not refer someone to us or share their contact information with us unless you have their permission to do so.

How We Use Your Personal Information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

To operate the App. We may use your personal information to:

• provide, operate, and improve the App, the Service, and our business, including improving the accuracy of REAL’s Authentication Engine
• establish and maintain your user profile on the App
• enable security features of the App, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in
• facilitate your invitations to friends who you want to invite to join the App
• communicate with you about the App, including by sending announcements, updates, security alerts, and support and administrative messages
• understand your needs and interests, and personalize your experience with the App and our communications
• provide support for the App
• respond to your requests, questions, and feedback regarding the App

To operate Coin Properties. We may use your personal information to:

• provide, operate, administer, and improve the Coin Properties and our business
• help you to facilitate the conversion between tokens and fiat currency
• communicate with you about the Coin Properties, including by sending announcements, updates, security alerts, and support and administrative messages
• understand your needs and interests, and personalize your experience with the Coin Properties and our communications
• provide support for the Coin Properties
• respond to your requests, questions, and feedback about the Coin Properties

To operate the Site. We may use your personal information to:

• provide, operate, and improve the Site and our business
• provide information about our products and services
• establish and maintain your user profile
• enable security features of the Site, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in
• facilitate your invitations to friends who you want to invite to join the Service
• communicate with you about the Site, including by sending announcements, updates, security alerts, and support and administrative messages
• understand your needs and interests, and personalize your experience with the Site and our communications
• provide support for the Site
• respond to your requests, questions, and feedback regarding the Site

For research and development. We may collect and use your personal information for research and development purposes, including to analyze and improve the Service and our business.

To send you marketing and promotional communications. We, our service providers, and our third-party advertising partners may collect and use your personal information for marketing purposes, including direct marketing.  We may send you REAL-related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the Opt out of marketing section below.

To manage our recruiting and process employment applications.  We may use personal information, such as information submitted to us in a job application, to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics.  

For compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities
• protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims)
• audit our internal processes for compliance with legal and contractual requirements or our internal policies
• enforce the terms and conditions that govern the Service
• prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft

With your consent. In some cases, we may specifically ask for your consent to collect, use, or share your personal information, such as when required by law.

To create anonymous, aggregated, or de-identified data. We may create anonymous, aggregated, or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated, or de-identified data by removing information that makes the data identifiable to you. We may use this anonymous, aggregated, or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Retention.  We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.  To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements.  

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

How We Share your Personal Information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, and website analytics).

Third-party payment processors. Third-party payment processors who provide certain services for users of the Coin Properties (including without limitation for identity verification and anti-money laundering prevention). We do not control the third party’s use of your personal information. Our third-party payment processor has the right to use the data that you provide for its own purposes, as described in its privacy policy available at https://www.tilia.io/legal/privacy .

Third parties designated by you. Third parties where you have instructed us or provided your consent to do so. We will share personal information that is needed for these other companies to provide the services that you have requested. 

Business and marketing partners. Third parties with whom we collaborate on joint activities (such as co-sponsors of contests and promotions), with whom we have entered into joint marketing relationships or other joint ventures, or who we think may offer you products or services that you may enjoy.

Third-party platforms and social media networks. If you have enabled features or functionality that connect the Service to a third-party platform or social media network (such as by logging in to the Service using your account with the third party or otherwise linking your account with the Service to a third party’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.

Professional advisors. Professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees.  Acquirers and other relevant participants in business transactions (or negotiations and diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, REAL or our affiliates (including, in connection with a bankruptcy or similar proceedings).  

Other users and the public.  Your profile and other user-generated content (except for messages) are visible to other users of the Service and the public. For example, other users of the Service or the public may have access to your information if you chose to make your profile or other personal information available to them through the Service, such as when you provide comments, reviews, survey responses, or share other content. This information can be seen, collected, and used by others, including being cached, copied, screen captured, or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of information.

We make commercially reasonable efforts to verify that the parties with whom our mobile application shares personal information provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as described in their own privacy policies.    

Your Choices

You have the following choices with respect to your personal information.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails you may continue to receive service-related and other non-marketing emails.

Cookies.  Most browsers let you remove or reject cookies.  To do this, follow the instructions in your browser settings.  Many browsers accept cookies by default until you change your settings.  Please note that if you set your browser to disable cookies, the Service may not work properly.  For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information.  We need to collect personal information to provide certain services.  If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Third-party platforms. If you choose to connect to the Service through a third-party platform or social media network, you may be able to use your settings in your account with that platform to limit the information we receive from it.  If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Remove or anonymize your content.  You may request that the content that you posted to the Service be removed or anonymized such that your personal information will not be publicly identifiable on the Service by contacting us at support@stim.io.  We may decline to process your request as consistent with law.  Please note that even if we process your request, it does not ensure complete or comprehensive removal of the content or information posted on the Service.  

Delete your content or close your account. You can choose to delete certain content through your account.  If you wish to request to close your account, please contact us at support@stim.io.

Other Sites and Services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be included on web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications, or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.

Security

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

International Data Transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Children

The Service is not intended for use by children under 18 years of age. If we learn that we have collected personal information through the Service from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it. We encourage parents or guardians with concerns to contact us at support@stim.io.

Changes to this Privacy Policy 

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Site and App. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail or another manner through the Service.

Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to Contact Us

• Email: support@stim.io
• Mail: 312 Arizona Ave, Santa Monica, CA. 9401
• Phone: [+1 (909) 324-3481

Your California Privacy Rights

Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes and the categories of personal information disclosed.  You may send us requests for this information to support@stim.io.  In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.