XRAI Glass is a companion software application (“XRAI Glass”), which pairs with Nreal Air Augmented Reality Glasses manufactured by Nreal Technology Limited[1] and distributed by EE Limited[2] (the “Device”), designed for use by hearing impaired individuals to transcribe and translate audio recordings into plain text and overlay captioned text boxes on to users’ live visual interactions with other individuals.
For users subscribing to XRAI Glass’ premium tier (or a trial of the premium tier), Audio Content will be shared with third-party cloud services providers to deliver transcription, translation and personal assistant functionalities. Otherwise, all Audio Content is processed locally on a user’s mobile device for the period in which XRAI Glass is open (the “Session”). Once a Session has ended, all Audio Content is automatically deleted from a user’s mobile device, if the user has enabled record session audio in the settings, then the audio content will remain on-device.
XRAI Limited, a company registered in England and Wales under company number 14164476, having its registered office at 71-75, Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ (the “Company,” “we,” or “us”) wants you to be familiar with how we collect, use and disclose Personal Information.
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. This Privacy Notice describes our processing practices of Personal Information that we collect and use in connection with:
- websites operated by us from which you are accessing this Privacy Notice (the “Websites”);
- software applications made available by us for use on or through computers and mobile devices (the “Apps”);
- our social media pages from which you are accessing this Privacy Notice (collectively, our “Social Media Pages”); and
- e-mail messages that we send to you or other communications with you.
Collectively, we refer to the Websites, Apps, Social Media Pages, and emails as the “Platforms”.
1 Nreal Technology Limited is a company registered in the People’s Republic of China, having its principal office at 15/F, A2 Avic Plaza, Haidian District, Beijing, China, 100098.
2 EE Limited is a company registered in England and Wales under company number 02382161, having its registered office at Trident Place, Mosquito Way, Hatfield, Hertfordshire, United Kingdom, AL10 9BW.
Collection and Processing of Personal Information
How we collect Personal Information
We collect Personal Information in a variety of ways, including through our Platforms and from other sources, as set out in the grids below.
We need to collect certain Personal Information in order to provide the requested Platforms to you. If you do not provide the information requested, we may not be able to provide the Platforms. We will note which Personal Information is required to provide the Platforms at the time of its collection.
If you disclose any Personal Information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.
Processing of Personal Information
We use your Personal Information for legitimate business purposes, as described in the overview below.
Making our Platforms available to users
|
Purpose |
Examples of Processing Activities |
Legal Basis |
Third Party Sources |
|
|
Providing the functionality of the Platforms |
Provide the functionality of the Platforms, such as arranging access to a user’s online account; facilitating a user’s purchases; verifying a user’s information; and processing a user’s subscription. |
Name & Contact Details; Account Information; Preferences; Relationship History; Transaction Information; Device Information; and Social Media Information. |
Performance of the contract, including the End User License Agreement that we enter into with users to provide the Platforms. |
Single-sign-on service providers. |
|
User-care service |
Administering user-care services to facilitate and address inquiries, requests, comments and complaints about any of our Platforms (such as by phone, email, or on social media), for example, to send users documents or information users request, or to assist users in using the Platforms. |
Name & Contact Details; Account Information; Relationship History; Transaction Information; Device Information; and Preferences. |
Performance of the End User License Agreement that we enter into with users to provide the Platforms. Legitimate interests, such as responding to inquiries or complaints. Legal obligations*, such as when users submit a request to access their Personal Information. |
N/A |
|
Communicating important changes / Service messages |
Send to you important information regarding our relationship with you, our Platforms, any changes to our terms, conditions, policies and procedures, and/or other administrative information. |
Name & Contact Details; Account Information; Preferences; Relationship History; Transaction Information; Device Information; and Social Media Information. |
Legitimate interests, such as to ensure our Platforms are used in accordance with our terms, conditions, and policies. Performance of contract, where provided in our End User License Agreement. Legal obligations*, such as to inform users of material changes to our End User License Agreement to comply with applicable consumer and/or data protection laws. |
N/A |
|
Operations and general business |
Administering online Platforms (including troubleshooting and diagnostic testing, conducting performance analyses of our systems and Platforms, testing new system features to evaluate their impact, system and log maintenance, technical support, system debugging, and the hosting of data); employee training and managing work activities and personnel generally; and facilitating mergers, acquisitions and other reorganizations and restructurings of our business (including prospective transactions).** |
Personal Information as relevant for the specific business operation. |
Legitimate interests, such as responding to user complaints and concerns. Legal obligations*, for example, relating to financial transactions, such as the obligation to maintain books and records. |
Third party organizations, when they share Personal Information with us to, for example, facilitate mergers, acquisitions and other reorganization and restructurings of our business. |
Marketing and user engagement
|
Purpose |
Examples of Processing Activities |
Legal Basis |
Third Party Sources |
|
|
Marketing |
Send you promotional information about our Platforms, newsletters, promotions, offers and other news about our Company. |
Name & Contact Details; Account Information; Relationship History; Transaction Information; Preferences; Marketing Data; End-User Content; Device Information; and Social Media Information. |
Legitimate interests, such as to promote our Platforms. Consent, for example, where we would like to send you direct SMS and email marketing communications, but do not have an existing relationship with you, we will ask for and rely on your prior opt-in consent. |
Third party organizations, for example, the Royal National Institute for Deaf People or other charities. |
|
Relationship building and engagement |
Facilitate and respond to any reviews, social sharing and posts on our Platforms. |
Name & Contact Details; Account Information; Marketing Data; Social Media Information; and End-User Content. |
Legitimate interests, such as engaging with individuals who post on our Social Media Pages. |
N/A |
Personalization and improving our Platforms
|
Purpose |
Examples of Processing Activities |
Legal Basis |
Third Party Sources |
|
|
Personalizing our Platforms |
Personalize our interactions with you and provide you with information and/or offers tailored to your interests, such as targeted advertising tailored to your interests, on our online Platforms; deliver content via our Platforms that we believe will be relevant and interesting to you. To carry out these purposes, we may use automated means, including profiling. |
Name & Contact Details; Account Information; Marketing Data; Social Media Information; Relationship History; Transaction Information; Device Information; and Preferences. |
Consent, for example, where we would like to send you offers tailored to your specific interests, purchase history and/or behavior, and such tailoring of offers would result in extensive profiling. Legitimate interests, such as providing tailored Platforms based on past usage and/or preferences, and such tailoring would be based on basic and privacy-non-intrusive segmentation. |
N/A |
|
Improving and developing new Platforms |
Conduct data analysis, for example, monitoring and analyzing usage of Platforms and using data analytics to improve the efficiency of our Platforms; develop new Platforms; consider ways for enhancing, improving, repairing, maintaining or modifying our current Platforms; identify usage trends, for example, understanding which parts of our Platforms are of most interest to users; determine the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and operate and expand our business activities, for example, understanding which parts of our Platforms are of most interest to our users so we can focus our energies on meeting our users’ interests. |
Name & Contact Details; Account Information; Relationship History; Transaction Information; Preferences; End-User Content; Device Information; and Social Media Information. |
Legitimate interests, such as developing new Platforms. Consent, such as when we use cookies and similar technologies and the data collected by means of such technologies qualify as Personal Information. |
N/A |
|
Aggregating and/or anonymizing Personal Information |
Aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. |
Personal Information as relevant for the specific business purpose. |
Legitimate interests, such as to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual. |
N/A |
Security and legal reasons
|
Purpose |
Examples of Processing Activities |
Legal Basis |
Third Party Sources |
|
|
Fraud prevention and security |
Conduct audits, verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements; monitor for and prevent fraud; and security purposes, including system security. |
Name & Contact Details; Account Information; Device Information; Relationship History; and Transaction Information. |
Legal obligations*, such as to detect and prevent cyberattacks. Legitimate interests, such as identifying and/or preventing fraudulent transactions. |
Single-sign-on service providers. |
|
Legal and compliance |
Fulfil our legal and compliance-related obligations [hyperlink to ‘Other Disclosures’], including complying with applicable laws; complying with legal processes; responding to requests from public and government authorities; meeting national security or law enforcement requirements. Enforcing our terms and conditions; protecting our operations; protecting the rights, privacy, or property of the Company; and allowing us to pursue available legal remedies, defend claims and limit the damages that the Company may sustain. |
Personal Information as relevant for the specific legal action, regulatory investigation, and/or legal processes in question, which may include: Name & Contact Details; Account Information; End-User Content; Preferences; Marketing Data; Relationship History; Transaction Information; Social Media Information; and Device Information. |
Legal obligations*, such as complying with legal processes. Legitimate interests, such as enforcing terms and conditions to protect trademarks and bringing or defending legal claims. |
Public and/or government and/or regulatory authorities, including courts, tribunals, regulators and government authorities. Third persons (legal or natural), as relevant for the specific legal action and/or processes in question (such as lawyers, auditors, insurers, advisory firms etc.). |
* For more information on our legal obligations, please see the section ‘Other Disclosures’ below.
** For more information on the disclosure of Personal Information in connection with a sale or business transaction, please see ‘Other Disclosures’ below.
Information we process on behalf of others
To the extent necessary to provide our services, we process Session Information and/or Audio Content on your behalf that is captured by you when using our Platforms and/or the Device.
Privacy, data protection and surveillance laws in your jurisdiction may apply to your use of our Platforms and/or the Device (including relating to the recording or sharing of Session Information and/or Audio Content). Capturing, recording or sharing Session Information and/or Audio Content that involves other people may affect their privacy rights. You are solely responsible for ensuring that you comply with any privacy, data protection, surveillance, or other applicable laws when you use our Platforms and/or the Device. For example, you may need to provide notice, obtain consents and/or process any rights requests from third parties with respect to your use of the Platforms and/or the Device, such as other individuals who interact with you while you are using our Platforms and/or the Device.
Personal Information
We collect the following categories of Personal Information:
A) Personal Information that we receive from you:
|
Name & Contact Details |
Such as first and last name, telephone number, and email address. |
|
Account Information |
Such as your chosen username, and other information you share in your account. |
|
End-User Content |
Such as reviews about Platforms, posts on our Social Media Pages, blogs, and comment sections. |
|
Preferences |
Such as language, interests, and other user feedback/preferences that you might express during your use of our Platforms. |
|
Marketing Data |
Such as your choices regarding our newsletters, surveys, and other marketing/advertising displayed or provided to you, and preferred methods of such promotional communication. |
|
Relationship History |
Such as details of your communications with us, and details of your claims, complaints and queries in general. |
|
Transaction Information |
Such as details of Platforms you have purchased from us. |
|
End-User Contacts |
Such as first and last name, telephone number, and email address of contact records of individuals |
|
Session Information |
Such as the output of transcriptions. |
|
Audio Content |
Such as audio recordings that are captured by users when using our Platforms and/or the Device. |
B) Personal Information that we collect through your use of our Platforms or from other sources:
|
Social Media Information |
Such as profile pictures, social media account ID, and other social media profile information, including lists of friends/followers on social media. |
|
Device Information |
Such as information about your devices and your use of our Platforms, including how you interact with the Platforms and information about the device itself, such as [the hardware model, operating system, IP addresses and browser type]. This includes data obtained through cookies and similar technologies, as described in our cookies and similar technologies policy. |
|
Session Information |
Such as the output of transcriptions. |
|
Audio Content |
Such as audio recordings that are captured by users when using our Platforms and/or the Device. |
|
Disclosure of Personal Information We disclose Personal Information for the purposes described in the table below: |
|
|
Recipients |
Purpose |
|
Website hosting service providers |
- Improving and developing new Platforms - Operations and general business - Providing the functionality of the Platforms |
|
Information technology and related infrastructure service providers |
- Fraud prevention and security - Improving and developing new Platforms - Operations and general business - Providing the functionality of the Platforms |
|
Email delivery service providers |
- Communicating important changes - User-care service - Improving and developing new Platforms - Marketing - Personalizing our Platforms - Providing the functionality of the Platforms - Relationship building and engagement |
|
Advertising networks |
- Improving and developing new Platforms - Marketing - Personalizing our Platforms - Relationship building and engagement |
|
User-care service or related benefits (including special promotions) service providers |
- Communicating important changes - User-care service - Improving and developing new Platforms - Marketing - Providing the functionality of the Platforms - Personalizing our Platforms - Relationship building and engagement |
|
Analytics providers for our Platforms |
- Aggregating and/or anonymizing Personal Information - User-care service - Fraud prevention and security - Improving and developing new Platforms - Marketing - Operations and general business - Personalizing our Platforms - Relationship building and engagement |
|
Law enforcement, public, regulatory and government authorities, courts or tribunals |
- Fraud prevention and security - Legal and Compliance |
|
Auditing service providers |
- Fraud prevention and security - Legal and Compliance |
|
Other services, including, without limitation, our Social Media Pages |
- Individual user public interactions and communications, such as message boards, chat, profile pages, blogs and other services to which you choose to post information - Social sharing activities |
Connecting to the Platforms via single-sign-on service providers
When you sign up and log in to the Platforms through a third party application, such as your Google account, you authorize us to collect certain Personal Information for account authentication purposes. Upon sign up, Google will ask your permission to share certain information from your Google account with us. This includes [your name and email address]. This information is collected by Google and is provided to us under the terms of Google’s privacy policy. You can regulate the information that we receive from Google using your Google activity controls.
Other Disclosures
We also disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so, as set out in further detail below. We may disclose your Personal Information to:
- Comply with applicable law and regulations.
- This may include laws outside your country of residence, which could give rise to a legal obligation requiring us to process your Personal Information, including when (i) we receive a court order to disclose information for the purposes of court proceedings, (ii) we are required to comply with requests and orders from law enforcement to provide information in relation to a criminal investigation, or to take steps to report information we believe is important to law enforcement where so required or advisable under applicable local laws, or (iii) we receive requests from competent authorities, such as data protection or consumer protection authorities.
- For dispute resolution purposes, and to protect our rights, privacy, safety or property, you or others.
- In connection with a sale or business transaction.
- We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any insolvency, bankruptcy or similar proceedings). You will be notified of any such business transaction and of possible changes to the processing of your Personal Information in accordance with applicable law and the ‘Updates To This Privacy Notice’ section.
Cookies & Similar Technologies
We may collect personal information through the use of cookies and similar technologies. Please see our cookies and similar technologies policy for more information.
Security
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
Choices and Individual's Rights
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes.
You may opt out from receiving marketing-related communications from us. If you no longer want to receive marketing related communications from us on a going-forward basis, you may opt out by (i) adjusting your account Settings [hyperlink to XRAI Glass account settings] and adjusting your marketing preferences, (ii) following the unsubscribe opt-out links on any marketing communications sent to you, and/or (iii) contacting us at any time at privacy@xrai.glass
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing from us, we may still send you important administrative messages, from which you cannot opt out.
How you can exercise your rights
If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, withdraw your consent (which will not affect the lawfulness of processing prior to the withdrawal), or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase, you may not be able to change or delete the Personal Information provided until after the completion of such purchase).
You may lodge a complaint with the UK’s Information Commissioner’s Office through here.
Retention Period
We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law, for example, for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
The criteria used to determine our retention periods include (i) the length of time we have an ongoing relationship with you and provide the Platforms to you (for example, for as long as you have an account with us or keep using the Platforms); (ii) whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Where a legal obligation arises or retention is advisable in light of our legal position, in some circumstances, we will retain certain Personal Information, even after your account has been deleted and/or we no longer provide the Platforms to you; for example:
- To cooperate with law enforcement or public, regulatory and government authorities: If we receive a preservation order or search warrant related to your Platforms account, we will preserve Personal Information subject to such order or warrant after you delete your Platforms account.
- To comply with legal provisions on tax and accounting: We may retain your Personal Information, such as Relationship History, and/or Transaction Information, for up to 7 years after you delete your Platforms account, as required by tax law and to comply with bookkeeping requirements.
- To pursue or defend a legal action: We may retain relevant Personal Information in the event of a legal claim or complaint, including regulatory investigations or legal proceedings about a claim related to your Personal Information, or if we reasonably believe there is a prospect of litigation (whether in respect of our relationship with you or otherwise) after the dispute has been settled or decided by a court or tribunal from which there is no further right of appeal.
Third-party services
This Privacy Notice does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Platforms link. The inclusion of a link on the Platforms does not imply any endorsement of the linked site or service by us.
The Platforms may provide functionality allowing you to make payments to the Company using third-party payment services with which you have created your own account. When you use such a service to make a payment to us, your Personal Information will be collected by such a third party and not by us and will be subject to the third party’s privacy notice rather than this Privacy Notice. We have no control over and are not responsible for this third party’s collection, use, and disclosure of your Personal Information.
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Google, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
Use of the platforms by minors
The Platforms are not directed to individuals under the age of thirteen (13), and we do not knowingly collect Personal Information from individuals under 13.
Jurisdiction and Cross-Border Transfer
Your Personal Information may be stored and processed in countries where we have facilities or in which we engage service providers [hyperlink to list of key services providers], and by using the Platforms, you understand that your Personal Information will be transferred to countries outside of your country of residence, including the United States and Germany, which may have data protection rules that are different from those of your country.
Where this will involve transferring your Personal Information outside the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Adequacy Decisions: Some non-UK countries are recognized by the Secretary of State as providing an adequate level of data protection according to UK standards (the full list of these countries is available here).
Standard Contractual Clauses: If we transfer Personal Information from the UK to countries which are not considered adequate under the UK GDPR, we have put in place the UK’s international data transfer agreement for international data transfers (the “UK IDTA”) to protect your Personal Information. You may obtain a copy of the UK IDTA by contacting us in accordance with the “Contacting Us” section below or by following this link. “UK GDPR” has the meaning given to it in section 3(10) (as supplemented by section 205(4)) of the Data Protection Act 2018.
Sensitive Information
Unless we request it, we ask that you not send us, and you do not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Platforms or otherwise to us.
Updates to this Privacy Notice
The “Last Updated” legend at the top of this Privacy Notice indicates when this Privacy Notice was last revised. Any changes will become effective when we post the revised Privacy Notice on the Platforms. If we make a material change to this Privacy Notice, we may notify you of this change, and depending on the nature of the change, we may seek your consent to the change.
Contacting us
XRAI Limited, a company registered in England and Wales under company number 14164476, located at 71-75, Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ, is responsible for the collection, use, and disclosure of your Personal Information under this Privacy Notice.
If you have any questions about this Privacy Notice, please contact us at privacy@xrai.glass
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.