Privacy Policy

Privacy Policy

Effective Date: October 23, 2022

This Privacy Policy explains what information of yours will be collected and used by VR2ality Infotec Pvt Ltd. (“VR2ality”, “we”, “us”, or “our”) when you access our website located at www.smarter.in as well as all related websites (together, the “Website”), the mobile applications provided by us (the “Apps”), and other services (collectively, together with the Website and the Apps, our “Service”). We will not use or share your information with anyone except as described in this Privacy Policy. Each time you use our Service you are accepting the practices described in this Privacy Policy at that time.
The Website is provided for information about our App. The Website is intended for adults only and does not allow game play.
The App downloaded to your device provides a learn and play experience (“SmartXR Kids”) and is intended for families and users of all ages.
Please read this policy in its entirety, including our Children’s Privacy Policy section, before using our Services. The Children’s Privacy Policy will control over any conflicting provisions in our general Privacy Policy as it concerns children’s data.

Children’s Privacy Policy

Protecting the privacy of children is especially important.
Website: The Website is not intended for children, does not market to children, and does not knowingly collect personal information from children. All references to “children” or “child” in this Children’s Privacy Policy shall mean children under 13 years of age, and all references to the term “parent” shall include legal guardians. If you are under 13 years of age, then please do not use or access the Website at any time or in any manner. If we learn that personally identifiable information has been provided to us and/or collected on the Website from persons under 13 years of age and without verifiable parental consent, such as through a support request, we take the appropriate steps to delete this information. If you are a parent and discover that your child under 13 years of age has provided personal information through the Website, then you may alert us at info@smartxr.in and request that we delete that child’s information from our systems. A parent or teacher can visit his or her account at any time to delete any information and/or the account.
App: We encourage parents and teachers to supervise their child or student’s use of the App. No personal information is collected or solicited from a child user of the App. We may collect analytics data (which does not contain personal information) from a child’s use of the App in order to offer and develop the Service, and we may collect information about a child such as age and nickname from you as part of your use of the App and the creation of your child’s user profile. We strive to keep the level of information collected from your child to a minimum, and in no event do we collect more information than what is required to use our learning app. The App contains no external links to third-party websites or services. We require all users of the App to use a parent or guardian’s email address in order to create an account. If permission is not received within 14 days from the email account holder, the account will be deleted. In order to enable interactive features, such as Workbooks, the App may request permission to access your device’s camera. Images captured by your device’s camera are processed only on your device by the App and are never saved. We do not receive the images captured by your device.

Information We Collect

Personal Information You Provide
You may provide and we may collect personal information about you when you create a profile and subscribe to the service, such as your email address and phone number. Your credit card information is collected by third party payment processors (e.g., Apple App Store or Google Play Store) and not by us. You may also provide us with information about the child using the Service, such as name or nickname and grade. You can choose not to provide any information that is affirmatively requested of you. However, this may limit your ability to use the Services.
We may also collect information from you if you communicate with us over the phone or via email. This information may include personal information. This information may be matched with and stored in connection with personal information provided or collected in connection with the Website.
Information Collected Automatically
We collect log file information that is automatically reported by your device each time you access our Services. For example, when you access the Website, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your web request, browser type, referring/exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other similar information which constitutes personal information.
We may use mobile analytics software and various backend systems to analyse certain information regarding your use of the Services such as page views, and transactionrelated information that may constitute personal information.
In general, we will store this information in an anonymous aggregated form; however, our third-party tracking partners may store certain information, such as page views, in a manner that can be associated to specific users and may constitute personal information. We use persistent and session cookies on our Website. A persistent cookie remains on your hard drive after you close your browser and may be used by your browser on subsequent visits to the Website. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, you may experience some changes in your ability to use the Website.
We do not collect specific information about your location from your mobile device, but we do log your IP address, which can be used to approximate location. We use IP addresses only for activities necessary to maintain or analyse the Service; perform network communications; authenticate users or personalise content; protect the security or integrity of the user and the Service; ensure legal or regulatory compliance; or fulfil a request of a user.

How We Use Your Information

Purposes
We may use information we collect for a variety of purposes, including:
To operate the Service, monitor the effectiveness of the Service, improve the content of the Service, and improve layout and design.
To help provide you with a smooth, efficient user experience.
To monitor, analyse, and describe usage patterns and performance of the Service, including aggregate metrics such as total number of visitors, traffic, and demographic patterns.
To conduct system administration and system troubleshooting and to diagnose or fix technology problems.
To comply with legal requirements and processes (for example, in response to subpoenas, court orders, and law enforcement or governmental requests or investigations), and to protect our legal rights or the rights of others (for example, by working to reduce the risk of fraud or misuse of the Service).
To enforce our Terms of Use or other policies or agreements
With respect to information collected through the Website described in the Information Collected Automatically section above, to assist in marketing efforts, including, for example, by tailoring and serving advertisements, and by tracking the effectiveness of marketing efforts.
In connection with a business transaction, such as the bankruptcy or liquidation of, sale of, purchase of, or merger with our business or another business.
Data Retention
We will retain your information for as long as is reasonably necessary in relation to the purposes for which this data was collected. In many instances, we will retain your data while it is necessary for your use of the Service, which may include maintaining this information beyond when you cease using the Service.
For instance, VR2ality may retain users’ data for the following purposes:
To develop new features and improve the Service;
To support subsequent customer service inquiries;
To improve the safety and security of the Service; or
Comply with our legal obligations.

How We Share Your Information

Personal Information
VR2ality will not rent or sell your personal information to others, nor will we share your personal information with independent third parties for marketing purposes. To operate the Service, however, we may share your personal information with our agents, representatives, and contractors so they can provide us with support services and other features. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.
Below are categories of recipients of your personal data and some examples of the thirdparties in that category. If you would like more information on any of these categories or specific recipients, please contact us at info@smartxr.in:
Video Platform (YouTube and Vimeo)
Analytics (Firebase)
Data Warehousing (Amazon Web Services)
Links to the privacy policies of the third party services are given below for your reference.
Non-Personally Identifiable Information
We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Website.
Instances Where We are Required to Share Your Personal Information
VR2ality will disclose your personal information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of VR2ality Infotec, our users or others. It is our policy to provide notice to our users before producing their personal information in response to law enforcement requests unless (i) we are prohibited by law or court order from doing so, (ii) we have reason to believe the user’s account has been compromised such that the notice would go to the wrong person, or notice would otherwise be counterproductive or would create a risk to safety, or (iii) it is an emergency request and prior notice would be impractical (in which case we may provide notice after the fact).

How We Share Your Information

Personal Information
VR2ality will not rent or sell your personal information to others, nor will we share your personal information with independent third parties for marketing purposes. To operate the Service, however, we may share your personal information with our agents, representatives, and contractors so they can provide us with support services and other features. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.
Below are categories of recipients of your personal data and some examples of the thirdparties in that category. If you would like more information on any of these categories or specific recipients, please contact us at info@smartxr.in:
Video Platform (YouTube and Vimeo)
Analytics (Firebase)
Data Warehousing (Amazon Web Services)
Links to the privacy policies of the third party services are given below for your reference.
Non-Personally Identifiable Information
We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Website.
Instances Where We are Required to Share Your Personal Information
VR2ality will disclose your personal information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of VR2ality Infotec, our users or others. It is our policy to provide notice to our users before producing their personal information in response to law enforcement requests unless (i) we are prohibited by law or court order from doing so, (ii) we have reason to believe the user’s account has been compromised such that the notice would go to the wrong person, or notice would otherwise be counterproductive or would create a risk to safety, or (iii) it is an emergency request and prior notice would be impractical (in which case we may provide notice after the fact).

Processing Personal Data

Your Choices About Your Information
You may, of course, decline to share certain personal information with us, in which case we may not be able to provide to you some of the features and functionality of the Service. You may update, correct, or delete your profile information and preferences at any time by accessing your account preferences page on the App or contacting us at info@smartxr.in. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. To update, correct, or delete any other personal information, please see the Individual Rights section below for more information.
If you receive promotional email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving promotional email from us, and any other promotional communications that we may send to you from time to time, by sending your request to us by email at info@smartxr.in. Please be aware that if you opt-out of receiving promotional email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving promotional messages from us, you will continue to receive administrative messages from us regarding the Service.
Individual Rights
VR2ality also makes certain choices available to you when it comes to your personal data. Please review the below information outlining your choices and how to exercise them. We will respond to all requests within a reasonable timeframe.
Review and Update Your Data
You have the right to access and update any personal data that we have collected. Some personal data, such as the account holder’s name and other details like location and phone number can be found and updated using the account management section in the parent zone inside the app. For any personal data beyond this, please submit a request using the contact information at the end of this section. We may request more information to confirm your identity before modifying any personal data.
Delete Your Data
You also have the right to have your personal data deleted. This is sometimes known as the ‘right to be forgotten’. To request that we delete all personal data about you, please submit a request using the contact information at the end of this section. We may request more information to confirm your identity before deleting any personal data.
Using the “Delete Account” function on the app which can be accessed from the parent zone WILL NOT automatically remove all of your personal data from our system. You must submit a request using the below information if you wish to delete all personal data from our system. After you delete your personal data from our services, we may not immediately delete residual copies from our active servers and may not immediately remove data from our backup systems, for archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. We may also decline to honour this request in certain specific situations, such as if the data is necessary to comply with a legal obligation or to exercise/defend a legal claim.
Delete Your Data
Using the “Delete Account” function on the app which can be accessed from the parent zone WILL NOT automatically remove all of your personal data from our system. You must submit a request using the below information if you wish to delete all personal data from our system. After you delete your personal data from our services, we may not immediately delete residual copies from our active servers and may not immediately remove data from our backup systems, for archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. We may also decline to honour this request in certain specific situations, such as if the data is necessary to comply with a legal obligation or to exercise/defend a legal claim.
Restrict Processing
You have the right to restrict how we process your personal data in certain circumstances. In some ways, this is an alternative to requesting the erasure of your data. Rather than requesting we erase all of your personal data, you may request that we limit our uses of your personal data to specific purposes. You may wish to request we restrict our processing if you contest the accuracy of your personal data and we are working to verify this information, or if you want us to retain your personal data in connection to a legal claim but cease processing it.
Data Portability

You have the right to obtain copies of your information in a structured, commonly used format that permits you to move your data between our service and the services of others. We may request more information to confirm your identity before providing any personal data.
Right to Object

You have the right to object to the processing of your personal data for direct marketing purposes or when our processing of your data is based on legitimate interests. You may request that we stop processing your personal data for direct marketing purposes. This is an absolute right and we cannot refuse this request. Beyond direct marketing, if you wish to exercise this right, you must give specific reasons why you object to our processing of your data, based on your particular situation. Even after receiving such a request, we may continue processing if it is necessary for the exercise/defence of a legal claim or if we can demonstrate a compelling legitimate ground for the processing.
If any request made under this section is manifestly unfounded or excessive, we may reject the request or require a reasonable fee to honour the request. If we decide to reject your request, we will inform you of the reasons for not taking action and provide information regarding other possible remedies. If we decide that a reasonable fee is necessary, we will promptly inform you and will comply with the request upon receipt of this fee.
Contact for Individual Rights Requests

Please use the below information when submitting a request to exercise any of the above rights. Please do not submit requests across multiple communications channels. We will make all efforts to respond to your request within a reasonable timeframe.
Email

info@smartxr.in
How We Protect Your Information – Security and Passwords

VR2ality takes what it believes to be commercially reasonable physical, electronic, and procedural safeguards to protect personal information. However, since no security system is impenetrable and “perfect security” does not exist on the Internet, we cannot guarantee the security of personal information. We have put in place procedures to respond to any suspected personal data breach and will notify you when we are legally required to do so.
If you create an account, you may be asked to choose a password. You should choose a password that is not easy to guess, and does not use words that you would find in a dictionary. Do not disclose your password to any other person. You are responsible for maintaining the confidentiality of your password and account, and we will attribute activities that occur using your account information (e.g., through the use of your password) to you. If you suspect that your password has been compromised, contact us immediately at info@smartxr.in.
Email and Recommendation Communications That We May Send

We may send you, or you may elect to sign up to receive, emails from us. To help us understand whether we are providing information of interest to you, we may include software code or other tracking technologies in our emails to monitor whether you opened a particular email, whether you have clicked on the images and/or links in the email, the date and time the message was opened, and whether your computer is capable of receiving HTML-based email. We endeavour to allow you to unsubscribe at any time from our email programs by clicking on the unsubscribe link at the bottom of any email message. We reserve the right to send you service announcements or similar administrative messages, without offering you the opportunity to opt out of receiving them.
Links To Third-Party Content

The Services may contain features or links to websites and services provided by third parties. Any information you provide on third-party websites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Website. We are not responsible for the content or privacy and security practices and policies of third-party websites or services to which links or access are provided through the Services. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

General

Updates to Our Privacy Policy
We reserve the right to update this Privacy Policy from time to time. When we do, we will revise the “Effective Date” at the top of this Privacy Policy. We encourage you to check this page periodically for any updates. If you continue to use the Service following the posting of an updated version of this Privacy Policy, we will treat your continued use as acceptance of the updated version.
If we make material changes to this Privacy Policy, we may notify you more prominently.
Contacting Us
If you have any remaining questions about how we treat your privacy, just let us know. You
can contact us by email at info@smartxr.in