REAL SOCIAL MEDIA DATING APPLICATION PRIVACY POLICY


Real Incorporated (“Real”) is a dating, networking, and social media application catered towards young professionals looking to find long-term romantic relationships. Real is owned by the Shinjiro Group, LLC, and is committed to protecting the privacy and security of your Personal Information, and complying with its obligations under applicable data protection law(s), including, but not limited to, the United States Privacy Act of 1974 (“US Privacy Act”) , Federal privacy laws, and state privacy laws, including, but not limited to, the California Consumer Privacy Act (“CCPA”), and Wyoming Genetic Data Privacy Act (“GDPA”).


This Privacy Policy (“Policy”) for Real ("we," "us," or "our"), describes how and why we might collect, record, organize, structure, store, adapt, alter, retrieve, consult, use, disclose, disseminate, or otherwise process ("Process") Personal Information when using our products and services, such as when you visit and use our website, application, or any website or application of ours that links to this privacy policy ("Services").


In this Policy, “Personal Information” is defined as information or an opinion about an identified individual, or an individual who is reasonably identifiable, directly or indirectly, and any other information that is deemed Personal Information under applicable data protection law.

Questions or Concerns? Reading this Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@realdatingnow.com.


  1. WHAT PERSONAL INFORMATION DO WE COLLECT?


    Personal Information You Disclose To Us

    We Process Personal Information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise contact us.


    Personal Information Provided By You. The Personal Information that we Process depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The Personal Information we Process and are displayed publicly include, but are not limited to the following:

    IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.


    Like many businesses, we also Process information through cookies and similar technologies. You can find out more about this in our Cookie Notice.


  2. HOW DO WE PROCESS YOUR INFORMATION?


    We may Process your Personal Information for a variety of reasons, depending on how you interact with our Services, in a manner that is compliant with applicable data protection laws, including:



  3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

    We may share your Personal Information with third-party vendors, service providers, contractors, agents, or external party outside of the Shinjiro Group ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We will only do so in a manner permitted by applicable data protection laws. We have contracts in place with our third parties, often called or referred to as “data protection agreements (“DPAs”) which are designed to help safeguard your Personal Information. This means that they cannot do anything with your Personal Information unless we have instructed them to do it. They will also not share your Personal Information with any organization apart from us. They also commit to protect the Personal Information they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share Personal Information with are as follows:


  4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?


    We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. We will only do so in a manner compliant with applicable data protection laws. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.


  5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?


    Our Services may offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider.


    We may use the Personal Information we receive only for the purposes that are described in this Policy or that are otherwise made clear to you on the relevant Services. We will do so in a manner compliant with applicable data protection laws. Please note that we do not control, and are not responsible for, other uses of your Personal Information by your third-party social media provider. We recommend that you review their privacy policy to understand how they use, share, or otherwise Process your Personal Information, and how you can set your privacy preferences on their sites and apps.


  6. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?


    We will only keep your Personal Information for as long as it is necessary for the purposes set out in this Policy and in a manner compliant with applicable data protection laws. When we have no ongoing lawful purpose of Processing your Personal Information prescribed by applicable data protection laws, we will either delete, anonymize, pseudonymize or otherwise encrypt such information in accordance with the law.


  7. HOW DO WE KEEP YOUR PERSONAL INFORMATION SAFE?


    We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any Personal Information we Process in a manner compliant with applicable data protection laws. However, despite our safeguards and efforts to secure your information, nonelectronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your Personal Information, transmission of Personal Information to and from our Services is at your own risk. You should only access the Services within a secure environment. If the Company is notified of a data or security breach affecting your Personal Information, we will notify you accordingly, as required by law. The Company is not responsible for data or security breaches that it does not have knowledge of.


  8. DO WE COLLECT PERSONAL INFORMATION FROM MINORS?

    We do not knowingly Process Personal Information from or market to individuals under 25 years of age. Specifically, you must be at least 25 years of age to create an account and we won’t knowingly process data for users under 25.


    By using the Services, you represent that you are at least 25 years of age or that you are the are the legal guardian, have power of attorney, or are otherwise legal caretaker of someone at least 25 years of age and consent to such dependent’s use of the Services. If we learn that Personal Information from users less than 25 years of age has been Processed or is otherwise incompatible with applicable data protection laws, we will deactivate the account and take reasonable measures to promptly delete such Personal Information from our records. If you become aware of any Personal Information we may have Processed from users under age 25 or that is incompatible with applicable data protection laws, please contact us at info@realdatingnow.com.


  9. WHAT ARE YOUR PRIVACY RIGHTS?


    Real respects your control over your Personal Information. You may have the following rights in relation to the Personal Information we hold about you, depending on your jurisdiction:


  10. SPECIFIC PRIVACY RIGHTS

    If you are a resident of Virginia, Utah, California, Colorado or Connecticut, you are granted specific rights regarding access to your Personal Information.


    Categorical Examples and Retention


    We may collect the following categories of Personal Information from time to time and in accordance with applicable data protection laws. In all cases, we keep the Personal Information for as long as the user has an account with us, and never for more than 6 months after in cases permitted by applicable data protection law. Should applicable data protection laws prescribe otherwise, we abide by the law in that jurisdiction.

    Category

    Examples

    A. Identifiers

    Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and

    account name

    B. Personal Information as defined

    Name, contact information, education, employment, employment history, and financial information

    C. Protected classification

    characteristics under state or federal law

    Gender and date of birth

    D. Commercial information

    Transaction information, purchase history, financial details, and payment information

    E. Internet or other similar network activity

    Browsing history, search history, online

    Behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

    F. Audio, electronic, visual, thermal, olfactory, or similar information

    Images and audio, video or call recordings created in connection with our business activities

    G. Professional or employment related

    information

    Business contact details in order to provide you our Services at a business level or job title, work history, and professional

    qualifications if you apply fora job with us

    H. Education Information

    Student records and directory information

    I. Inferences drawn from collected Personal Information

    Inferences drawn from any of the collected Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

    J. Sensitive Personal Information

    Account login information, debit or credit card number, contents of email or text messages, drivers' licenses, and citizenship or

    immigration status


    1. California Residents


      California Civil Code Section 1798.83, also known as the "Shine the Light" law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared Personal Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.


      This section applies only to California residents. Under the California Consumer Privacy Act (“CCPA”), you have the rights listed below.


      The California Code of Regulations defines a “resident” as:

      • every individual who is in the State of California for other than a temporary or transitory purpose and

      • every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose


        All other individuals are defined as "non-residents."


        If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your Personal Information.


        Your Privacy Rights


      • Right to request deletion of the Personal Information — Request to delete. You can ask for the deletion of your Personal Information. If you ask us to delete your Personal Information, we will respect your request and delete your Personal Information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any Processing that may be required to protect against illegal activities.

      • Right to be informed — Request to know. Depending on the circumstances, you have a right to know:

        • whether we Process and use your Personal Information;

        • the categories of Personal Information that we Process;

        • the purposes for which the Processed Personal Information is used;

        • whether we sell or share Personal Information to third parties;

        • the categories of Personal Information that we sold, shared, or disclosed for a business purpose;

        • the categories of third parties to whom the Personal Information was sold, shared, or disclosed for a business purpose;

        • the business or commercial purpose for Processing Personal Information; and

        • the specific pieces of Personal Information we Process about you.


          In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual Personal Information to verify a consumer request.


      • Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights. We will not discriminate against you if you exercise your privacy rights.


      • Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to direct us to limit our use of your sensitive Personal Information if we Process any of the following:

        • social security information, drivers' licenses, state ID cards, passport numbers;

        • account login information;

        • credit card numbers, financial account information, or credentials allowing access to such accounts;

        • precise geolocation;

        • racial or ethnic origin, religious or philosophical beliefs, union membership;

        • the contents of email and text, unless the business is the intended recipient of the communication;

        • genetic, biometric, and/or health data; and/or

        • Personal Information concerning sexual orientation and sex life;

      • Other rights.

        • You may object to the Processing of your Personal Information.

        • You may request correction of your Personal Information if it is incorrect or no longer relevant, or ask to restrict the Processing of the information.

        • You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

        • You may request to opt out from future selling or sharing of your Personal Information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.


          Once a business receives your request, they are no longer allowed to use or disclose your sensitive Personal Information for any other purpose unless you provide consent for the use or disclosure of sensitive Personal Information for additional purposes.


          Please note that sensitive Personal Information that is Processed without the purpose of inferring characteristics about a consumer is not covered by this right, as well as the publicly available information.


          Verification Process


          Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.


          We will only use Personal Information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.


          Financial Incentives


          "Financial incentive" means a program, benefit, or other offering, including payments to consumers as compensation, for the disclosure, deletion, sale, or sharing of Personal Information.


          The law permits financial incentives or a price or service difference if it is reasonably related to the value of the consumer’s Personal Information. A business must be able to explain how the

          financial incentive or price or service difference is reasonably related to the value of the consumer’s Personal Information. The explanation must include:

      • a good-faith estimate of the value of the consumer’s Personal Information that forms the basis for offering the financial incentive or price or service difference; and

      • a description of the method the business used to calculate the value of the consumer’s Personal Information.


        We may decide to offer a financial incentive (e.g., price or service difference) in exchange for the retention, sale, or sharing of a consumer’s Personal Information.


        If we decide to offer a financial incentive, we will notify you of such financial incentive and explain the price difference, as well as material terms of the financial incentive or price of service difference, including the categories of Personal Information that are implicated by the financial incentive or price or service difference.


        If you choose to participate in the financial incentive you can withdraw from the financial incentive at any time or by referring to the contact details at the bottom of this document.


        To submit a request to exercise these rights described above, please email us at

        info@realdatingnow.com.


    2. Colorado Residents


      This section applies only to Colorado residents. Under the Colorado Privacy Act (“CPA”), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.


      • Right to be informed whether or not we are Processing your Personal Information.

      • Right to access your Personal Information.

      • Right to correct inaccuracies in your Personal Information.

      • Right to request deletion of your Personal Information.

      • Right to obtain a copy of the Personal Information you previously shared with us.

      • Right to opt out of the Processing of your Personal Information if it is used for targeted advertising, the sale of Personal Information, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling").


        To submit a request to exercise these rights described above, please email us at

        info@realdatingnow.com.


    3. Connecticut Residents

      This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (“CTDPA”), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.


      • Right to be informed whether or not we are Processing your Personal Information.

      • Right to access your Personal Information.

      • Right to correct inaccuracies in your Personal Information.

      • Right to request deletion of your Personal Information.

      • Right to obtain a copy of the Personal Information you previously shared with us.

      • Right to opt out of the Processing of your Personal Information if it is used for targeted advertising, the sale of Personal Information, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling").


        To submit a request to exercise these rights described above, please email us at

        info@realdatingnow.com.


    4. Utah Residents


      This section applies only to Utah residents. Under the Utah Consumer Privacy Act(UCPA), you have the rights listed below. However, these rights are not absolute, Andin certain cases, we may decline your request as permitted by law.


      • Right to be informed whether or not we are Processing your Personal Information.

      • Right to access your Personal Information.

      • Right to request deletion of your Personal Information.

      • Right to obtain a copy of the Personal Information you previously shared with us.

      • Right to opt out of the Processing of your Personal Information if it is used for targeted advertising or the sale of Personal Information.


        To submit a request to exercise these rights described above, please email us at

        info@realdatingnow.com.


    5. Virginia Residents


      Under the Virginia Consumer Data Protection Act (VCDPA):


      "Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.


      "Personal Data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal Information" does not include de-identified Personal Information or publicly available information.

      "Sale of Personal Information" means the exchange of Personal Information for monetary consideration.


      If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your Personal Information.


      Your Privacy Rights


      • Right to be informed whether or not we are Processing your Personal Information

      • Right to access your Personal Information

      • Right to correct inaccuracies in your Personal Information

      • Right to request deletion of your Personal Information

      • Right to obtain a copy of the Personal Information you previously shared with us

      • Right to opt out of the Processing of your Personal Information if it is used for targeted advertising, the sale of Personal Information, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")


      To submit a request to exercise these rights described above, please email us at

      info@realdatingnow.com.


      Verification Process


      We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through unauthorized agent, we may need to Process additional information to verify your identity before Processing your request.


      Upon receiving your request, we will respond without undue delay, but in all cases, within forty- five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45- day response period, together with the reason for the extension.


      Right to Appeal


      If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at info@realdatingnow.com.

      Within sixty (60) days of receipt of an appeal, we will inform you inwriting of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.


  11. UPDATES


    We may update this Policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Policy frequently to be informed of how we are protecting your information.

  12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?


If you have any further questions or comments, you may also contact us via email

info@realdatingnow.com.


Last updated April 21, 2025