We, XRTY (hereinafter referred to as "XRTY" or "We") always believe that AR/VR (Augmented Reality/Virtual Reality) services involve personal information such as the profile of direct and indirect users which shall be protected in the most cautious manner. This Privacy Policy ("the Privacy Policy") is applicable to the XRTY ("the Platform") and/or all the personal information collected by the services of the XRTY ("the Services"). This Privacy Policy describes how we collect, use, disclose, store, and protect the personal information, as well as provides you with the access to your personal information collected and used by us.

1. Personal Information You Submitted to Us

We receive and store the personal information you provided on the Platform. If you are a user of the Platform and the Services, your personal information collected by us contains information that is identifiable of a specific identity, such as your name, e-mail address, Address which will be used for registration, account management, sending product updates or information to you, asking us questions, requesting your information and feedback (including through investigation, questionnaire and the like) and carrying out other matters or activities on our website. 

2. Personal Information Collected by Us Automatically and Its Intended Use

When you are visiting our website, we may collect certain information on your device, including your IP address, software model of the web browser, device model, unique device identification number, general address information (such as the country or the city), detailed location and other technical information and online activities (such as the web browsing history and clicking histories). Collecting such information facilitates us learning more about our Platform's visitors, such as where the visitors come from and what contents of our Platform are attractive to visitors, the objectives of improving the quality of our Platform and relevance, the implementation of business analysis, or other purposes concerning the improvement of the quality of our business, the website, API, services provided, etc. We will also keep a corresponding log of the operation status of our Platform. Generally, such information is collected through cookies adopted by us and similar tracking technologies. See the following part of "Information on Cookies and Similar Technologies" for details.

3. How We Use the Collected Information

Generally speaking, your personal information collected by us will only be used for purposes prescribed by the Privacy Policy or the purposes we inform you when collecting your personal information. If we use your personal information for additional purposes, we will obtain your consent in accordance with the provisions of laws and regulations.

4. Sharing and Disclosure of Personal Information

We will keep the personal information of you and your users confidential, and except for the following circumstances, we will not share your personal information with a third party:

  • Sharing the information with the service providers who obtained our authorization in order to perform certain functions or provide certain services on behalf of us (for example, for service providers, cloud service providers, advertising and marketing analysis service providers who support the safety and normal operation of our Platform);
  • Responding to summonses, court orders or other proceedings, or establishing or exercising our legal rights, or defending a legal claim;
  • Sharing within our affiliates, mainly for providing you with the corresponding services and/or products;
  • When we hold that it is necessary to investigate, prevent, or take actions with respect to the activities violating applicable laws and regulations, suspected fraud activities, and the defending activities concerning a legal claim or other activities required by laws;
  • When the information is required to be provided for protecting or defending the rights or assets of XRTY/the Platform or others and public safety;
  • Disclosure to the potential buyers of any part of our business concerning any proposed purchase, merger or acquisition, provided that we inform such buyers that they must use your personal information within the purposes disclosed by the Privacy Policy;
  • When your consent is obtained.

 

When our products or services cease operation, we will notify you by pushing notifications and announcements, and we will also delete or anonymously dispose your submitted personal information within a reasonable time limit.

5. Cross-border Data Transmission

Your or your users' personal information may be transmitted to other countries or regions outside your country for handling if you are an overseas user. The data protection laws in such countries or regions may differ from that of your country. However, we have taken corresponding protection measures to protect your personal information in accordance with the Privacy Policy.

6. Information on Cookies and Similar Technologies

We use Cookies and other similar tracking technologies (collectively, "Cookies") to collect and use your personal information.

Your personal information may be collected by Cookies for:

  • Providing you with better use experience and service;
  • Providing advertising/pushing services: When you visit the Platform, we will share your visiting behaviors, such as your clicks, time spent on the Platform, browser model to a third party for counting the number of users and daily active users;

Before sharing, we will require the third-party partners to strictly abide by the relevant provisions of the Privacy Policy.

Please note that when you disable the Cookies by changing the browser settings or enable the browser's "anonymous browsing" function, the Cookies will cease to collect your personal information. However, the corresponding functions on the webpage which may enhance your browsing experience will also be unavailable.

7. Channels for the Execution of Rights on Personal Information

You may update, change, obtain, or delete your or your user's personal information by sending an email to This email address is being protected from spambots. You need JavaScript enabled to view it.. We will respond to the request of you or your users for execution of the rights in accordance with relevant laws, and we may also verify the identity of you or your users so that we can cooperate with you or your users to exercise the legal rights of data subject.

We may not be able to respond to your request for the execution of rights if:

  • The information requested is inconsistent with the obligations stipulated by laws and regulations;
  • The information requested is directly associated with national security and national defense security;
  • The information requested is directly associated with public security, public health and major public interests;
  • The information requested is directly associated with the criminal investigation, prosecution, trial and execution of judgment;
  • There is reasonable evidence proving the existence of subjective malice or abuse of rights;
  • The legitimate interests of you or other individuals and organizations will be seriously damaged in the case of responding to your request for the execution of rights.
  • The information requested is related to trade secret.

Please send an email to This email address is being protected from spambots. You need JavaScript enabled to view it. for unsubscribing, and we will provide assistance accordingly.

8. Information Security

We have taken security measures that comply with the laws and regulations and industry practices to protect the personal information you have provided us. For example, we have established special management systems and procedures to ensure the security of the information.

However, an absolutely secure way of transmitting or storing electronic data is not available, and there is no guarantee that such information will never be accessed, used or published in a manner that violates the Privacy Policy. In case of unexpected security incident such as personal information disclosure, we will launch an emergency plan to control the expansion of the security incident and inform you by pushing notification, announcement and other forms.

9. Privacy of Minors

We attach great importance to the protection of the information of minors.

Our products, websites and services mainly target adults. If you are under the age of 18, you are required to visit our Platform or accept our services under the supervision and guidance of your parents or legal guardians; and you are not allowed to access to the Platform and the Services until obtaining the consent of your parents or legal guardians.

If you intend to upload the personal information of minor users on the Platform, please ensure that you have obtained the consent of the parents or legal guardians of such minor users before uploading. If the parents or legal guardians of the minor users disagree your acceptance of our services or providing information to us in accordance with the Privacy Policy, please delete the personal information of the minor users not agreed by the parents or legal guardians from our platform in a timely manner.

The Platform may have links to third-party websites, products and services. Such third-party websites, products and services are not subject to the Privacy Policy, so the information collected by such third parties is required to comply with their privacy measures. You are recommended to review the privacy statements of the third parties to understand their procedures of collecting, using and disclosing of the personal information they have collected.

11. App store data

The respective app stores, such as Apple’s App Store and Google Play, collect anonymous usage statistics, and disclose it to us. 

IOS App (XRTY Viewer) using ARKit, Camera APIs, Photo APIs and depth of facial mapping information, TrueDepth API

We do not collect, store or share data used by ARKit, Camera APIs, Photo APIs, or other software for depth of facial mapping information, TrueDepth API

Extra information regarding Face Filter functionality in XRTY viewer IOS App use of Apple's TrueDepth API : 

XRTY viewer face filter uses the device's TrueDepth camera system to track the face movement to apply face filter effect. This allows for a unique user experience — animated face filter with your face. In order to view augmented reality experience, the app requires access to your device's camera. This access can be toggled on or off at any time in your device's settings.

The resulting depth data are only used for face filter purposes. The live video feed is never used, and its data is never stored locally or remotely. Camera access is required to get depth data from Apple's API's.

This data is stored on the device only for the duration of your current augmented reality session. Every time the home screen is presented or the app is closed, the data is deleted. This data is used to make your augmented reality experience more enjoyable and prevent accidental jumps. 

Face data is never stored remotely, given to third parties, or used for any other purposes. The face data only remains on your device, and never leaves your device at any time.

 

12. Changes in the Privacy Policy

We may revise the Privacy Policy from time to time due to changes in business, technology or laws and regulations.

If such changes may result in a material loss of your rights under the Privacy Policy, we will notify you by giving an indication at a prominent position on the webpage, sending you an e-mail and other ways before the changes come into effect.

If you do not accept the changes, you may stop using our products or accepting our services; if you continue to accept our services, it will be deemed that you agree to be bound by the Privacy Policy after its revision.

Material changes to the Privacy Policy include but are not limited to:

  • Material changes in the service mode, such as, the changes in the purpose of handling personal information, the type of personal information handled, and the way how personal information is used.
  • Changes in the main object of the personal information shared, transferred or disclosed;
  • Material changes in your right to participate in the personal information handling and the way how you exercise it;
  • Other changes that may have a material impact on your personal information rights and interests.

12. Governing Law

The execution, effectiveness, performance, interpretation and dispute resolution of the Privacy Policy shall be governed by the law.

13. Contact us

Please send an email to This email address is being protected from spambots. You need JavaScript enabled to view it. for any questions about the Privacy Policy.

We will review the issues involved as soon as possible. Generally, we will reply within 30 days after verifying your identity.