Privacy Policy

Overview

This Privacy Policy (the “Policy”) describes how your personal information is collected, used, and shared when you visit, use, or effect a transaction (as applicable) from the RealTwin OÜ’s “RealTwin” website at realtwin.org and all subdomains, subscription platform, mobile application(s) (collectively, the “Site”), and services offered by RealTwin OÜ through all of these (collectively, the “Service”), unless otherwise specified. This policy is incorporated into the [Terms and Conditions] (the “Terms”) that govern your use of the Service. Any capitalized terms not defined in this Privacy Policy will have the definitions provided in the Terms. By using the Service, you consent to the practices described in this Policy.

Please note that this Policy does not apply to: information collected by us offline or through any other means, including on any other website that we operate or any third party (including our affiliates and subsidiaries); or information collected by any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Service.

Personal Information We Collect

We collect and process the following categories of personal information:

• Identifiers. This includes information such as your name, username, email, and contact information. If you use a third-party authentication tool, we may receive your username and email addresses associated with that service. We refer to this information as “Contact Information”
• Internet or Network Activity & Geolocation Data. When you visit the Site, we automatically collect certain information such as your IP address, browser type, operating system, and activity on our website such as the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. Additionally, we automatically collect information about your general location and some of the cookies that are installed on your device. We refer to this automatically-collected information as “Device Information”

Our Service is not intended for minors so we do not knowingly collect information from or about minors. If we discover that we collected information on a minor, we will promptly take corrective action. If you believe we have collected such information, please contact us at legal@realtwin.org

How do we collect personal information?

We collect personal information from:

• You. We collect personal information when you give it to us, such as when you fill out a form, log-in to the Service, or contact us.
• Your Devices. We collect personal information from your devices, often through the use of cookies or similar tools. Cookies (and similar tools) help us to provide you with a good experience when you browse our Service and also allows us to improve our Service. “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
• Third Parties. We receive personal information from our vendors, business partners, and any third-party authentication providers you use to access our site.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Contact Information.

By using the Site or providing us with Personal Information to communicate with us or complete a transaction, you are giving us your consent to collecting and using your Personal Information to communicate with you or complete the transaction, and for all of the other purposes described in this Policy, as applicable.

How Do We Use Your Personal Information?

We use, store, and process the Personal Information that we collect to provide and improve our Service, and to offer a secure, safe, and trusted experience. For example, we may use your Personal Information:

• to interact with the Site;
• to protect against or deter fraudulent, illegal, or harmful conduct;
• to provide you with information and other services that you may request from us;
• to carry out our obligations and enforce our rights arising from any contracts or agreements entered into between you and us;
• to notify you about changes to our Service or Products;
• to improve and optimize the Service;
• to allow you to participate in interactive features on the Site;
• to respond to correspondence we receive from you, and providing customer service;
• to resolve disputes;
• in any other way that we may describe at the time we provide the information (for instance, in connection with a contest or promotion);
• for any other purpose, with your consent;
• to comply with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, or for other purposes, as permitted or required by law; and
• as necessary or appropriate to protect the rights, property, and safety of our users, us, and other third parties.

We will keep your Personal Information only for as long as necessary to provide you with the Service, maintain our legitimate business operations, and/or exercise, defend or establish our rights. The precise length of time that we retain your Personal Information depends on why we collected it and how we use it, but we will not retain your Personal Information for longer than necessary for our business purposes or for legal requirements.

Disclosing Your Personal Information

Note that we may de-identify Personal Information so that it is non-personal, such as by aggregating it or converting it to a code, sometimes using a function known as a “hash.” We will treat de-identified information as non-personal to the fullest extent permitted by applicable law.

We share your Personal Information with third parties to help us use your Personal Information, as described above. We also currently use the following third party services for the following purposes:

Virtual Productions Cloud

Purpose: Providing the AI functionality in the Virtual Production Cloud plugin.

RealTwin OÜ uses open-source LLMs for AI content generation. We utilize existing pre-trained models to provide functionality within our platform. We run the models with our own infrastructure and do not disclose personal data to third parties, except for infrastructure service providers.

Third Party Service: Google Analytics

Purpose: To help us understand how our customers use the Site. Privacy Policy: https://policies.google.com/privacy?hl=en

We may disclose Personal Information that we collect or you provide, as well as information that you provide to us about third -parties, as described in this Policy:

• to our subsidiaries and affiliates;
• to service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
• to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of RealTwin OÜ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred;
• to fulfill the purpose for which you provide it;
• for any other purpose disclosed by us when you provide the information; and
• with your consent.

Third Party Service: Mailchimp

Purpose: To help us reach out to customers regarding our services, and provide updates on new products and features. Privacy Policy: https://www.intuit.com/privacy/statement/

We use third-party services, such as Mailchimp, for managing our email marketing campaigns. By using our Service and providing your email address, you agree that we may send you communications via email regarding our services, products, and offers that might interest you. You will have the option to opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

By subscribing to our email communications, you acknowledge and agree that your email address will be shared with such third-party services for the purpose of delivering the emails to you. We will handle your personal information in accordance with our Privacy Policy, ensuring compliance with the General Data Protection Regulation (GDPR).

Please note that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

We may also disclose your Personal Information:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• to enforce or apply our Terms and other agreements we may have with you; and
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of RealTwin OÜ, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Once you leave our Site or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our Terms.

What about third-party links on the Service?

Our Service may contain links to web properties operated by third parties. If you follow any of these links, your usage of that web property will be subject to the third-party’s privacy policy. We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

Your Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information that you provide to us and that we collect. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.

You also have the following rights concerning your personal information:

• Access. You may request that we provide you with a copy of the personal information we hold about you or that we provide you details about that information (such as what categories of data we collected, why we collected it, and what sources provided us the information).
• Deletion. You may request that we delete your personal information.
• Correction. You may request that we correct information you believe is inaccurate or complete information you believe is incomplete.
• Opt-out. You may request that we refrain from selling your personal information or sharing it for targeted advertising.

You, your authorized agent, or another person authorized by law may request to exercise the above rights. To exercise the above rights, or remove your account from our Service, please contact us via email at legal@realtwin.org.

Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures.

Additional Information for users in the UK, EEA and Switzerland

If you are a European Union resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. Additionally, if you are a European Union resident we note that we are processing your information in order to fulfill contracts we might have with you, to pursue our legitimate business interests listed above, or otherwise with your consent. Additionally, please note that your information will be transferred outside of the EEA, including to the U.S.

As a global company, RealTwin OÜ adheres to the General Data Protection Regulation (“EU GDPR”) and the UK General Data Protection Regulation (“UK GDPR”, together with the EU GDPR “GDPR”).

RealTwin OÜ is controller. Because RealTwin OÜ determines the means and purpose for which your personal information is processed, pursuant to the GDPR, RealTwin OÜ is the data controller with respect to your personal information.

Legal Bases for processing. We only process your personal information pursuant to one of the following legal bases:

• Consent. You provided us with consent to process your personal information.
• Contract. We may process your personal information to execute a contract with you or your employer.
• Legal Compliance. We may process your personal information to comply with our legal obligations.
• Legitimate Interest. Where it is necessary for us to process the information in order pursue our legitimate interests, including:
  • providing and improving our products and services;
  • maintaining the security and integrity of our offerings;
  • minimizing claims and financial losses for us, and our customers;
  • promoting our products, services and brand; and
  • conducting research and analytics.

Additional Rights. In addition to your rights specified above, you have the right to:

• object to our processing of your personal information,
• request that we restrict our processing of your information,
• transfer your personal information to another party
• withdraw your consent to any processing premised on your consent, or
• file a complaint with the applicable supervisory authority.

We will not discriminate against you for exercising any of your rights. To exercise these rights, please contact us by sending an email to legal@realtwin.org .

International Transfer. Because RealTwin OÜ is an international business, we may need to transfer your personal information out of the UK, EEA or Switzerland to other countries. We only transfer your information if (1) the recipient is in a country providing an adequate level of protection; (2) we use appropriate safeguards, such as standard contractual clauses; or (3) there is an applicable exception (such as consent). Please contact us at legal@realtwin.org if you would like additional information regarding the international transfer of your personal information.

Questions or concerns. If you have questions or concerns about our GDPR compliance, please contact us via email at legal@realtwin.org.

If you are in the UK, you may submit a complaint to the Information Commissioner’s Office (“ICO”) (www.ico.org.uk); however, we request that you first give us an opportunity to address your concerns before you contact the ICO.

Additional Information for users in California

In the last twelve months we have collected the personal information identified in the “Personal Information We Collect” section of this notice.

We do not intentionally collect sensitive personal information, as defined in the California Consumer Privacy Act. If you provide us with such information, we will only use that information for purposes permitted by California Civil Code section 1798.121(a) and the related regulations.

Do Not Track

We allow (and in the last 12 months we have allowed) trusted partners to collect personal information - namely internet or network activity - on your activity on our Service in order to improve our Service. California considers that to be selling or sharing your information for targeted advertising.

Although we do not currently respond to Do Not Track signals, we do provide other options for you to request that we do not sell or share your personal information. To opt-out of sharing or sale of your information follow the instructions in the “Your Choices About How We Use and Disclose Your Information” section of this notice.

Minors

Our Service is intended for a general audience and not for use by anyone younger than the age of 13. We do not knowingly collect personal information from children younger than the age of 13, without the consent of a parent or legal guardian; if we learn that we have done so, we will promptly remove the information from our active databases. If you are a parent or legal guardian who believes that we have collected or used your child’s personal information without your consent, please contact us at legal@realtwin.org.

Changes

We may update this Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons. It is our practice to post any changes we make to our Policy on this page with a notice that the Policy has been updated on the Site. If we make material changes to how we treat Personal Information, we will notify you through a notice on the Site. The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this Policy to check for any changes.

Contact Us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at legal@realtwin.org.