Introduction

We ("we", "us", "our") are committed to protecting the privacy of users ("User" or "you") of our website and/or mobile app (the "Website" or " Mobile App”) very seriously and we are committed to protecting the information that users provide to us in connection with the use of our Website and/or our Mobile App (collectively: “Digital Assets”). Furthermore, we are committed to protecting and using your information in accordance with applicable law.

This Privacy Policy explains our practices regarding the collection, use, and disclosure of your information through the use of our digital assets (the "Services") when you access the Services through your devices.

Please read the Privacy Policy carefully and ensure you fully understand our practices regarding your information before using our Services. If you have read and fully understood this policy and do not agree with our practices, you must stop using our digital assets and services. By using our services, you accept the terms of this privacy policy. Continued use of the Services constitutes your acceptance of this Privacy Policy and any changes thereto.

In this privacy policy you will learn:

• How we collect data
• What data we collect
• Why we collect this data
• Who we share the data with
• Where the data is stored
• How long the data is retained
• How we protect the data
• How we deal with minors
• Updates or changes to the Privacy Policy

What data do we collect?

Category: Always

Below is an overview of the data we may collect:

• Unidentified and non-identifiable information that you provide during the registration process or that is collected through the use of our Services ("Non-Personally Identifiable Information"). Non-personal data do not allow any conclusions as to who collected them. Non-Personally Identifiable Information that we collect consists primarily of technical and aggregate usage information.
• Individually identifiable information, i.  H. all those from which you can be identified or could be identified with reasonable effort ("personal data"). The Personal Information we collect through our Services may include information requested from time to time, such as names, email addresses, addresses, phone numbers, IP addresses and more. If we combine personal information with non-personal information, we treat it as personal information for as long as it is combined.

How do we collect data?

Category: Always

Below are the main methods we use to collect data:

• We collect data when you use our services. Therefore, when you visit our digital assets and use the Services, we may collect, record and store usage, sessions and related information.
• We collect data that you make available to us yourself, for example if you contact us directly via a communication channel (e.g.  an email with a comment or feedback).
• We may collect information from third party sources as described below.
• We collect information that you provide to us when you log into our Services through a third party such as Facebook or Google.

Why do we collect this data?

Category: Always

We may use your data for the following purposes:

• to provide and operate our Services;
• to develop, customize and improve our Services;
• to respond to your feedback, requests and requests and to offer assistance;
• to analyze request and usage patterns;
• for other internal, statistical and research purposes;
• to improve our data security and fraud prevention capabilities;
• to investigate violations and enforce our terms and policies and to comply with applicable law, regulation or governmental request;
• to provide you with updates, news, promotional materials and other information related to our Services. In the case of promotional e-mails, you can decide for yourself whether you wish to continue to receive them. If not, just click the unsubscribe link in those emails.

Who do we share this data with?

Category: Always

We may share your data with our service providers in order to operate our services (e.g. storing data via third-party hosting services, providing technical support, etc.).

We may also disclose your information in the following circumstances: (i) to investigate, detect, prevent, or address unlawful activity or other wrongdoing; (ii) to establish or exercise our rights of defense; (iii) to protect our rights, property, or personal safety, or the safety of our users or the public; (iv) in the event of a change of control of us or any of our affiliated companies (by way of a merger, acquisition or purchase of (substantially) all of the assets and  a.); (v) to collect, hold and/or manage your data using authorized third parties (e.g.  B. cloud service provider) as appropriate for business purposes; (vi) to work collaboratively with third parties to improve your user experience. To avoid misunderstandings, we would like to point out that we can transfer or pass on non-personal data to third parties or use them in any other way at our own discretion.

Category: User has a blog or forum

Please note that our Services enable social interactions (e.g. posting content, information and comments publicly and chatting with other users). We remind you that any content or data that you make available in these areas can be read, collected and used by other people. We do not recommend posting or sharing information that you do not want to make public. If you upload content to our digital assets or otherwise make it available as part of using any service, you do so at your own risk. We cannot control the actions of other users or members of the public with access to your data or content. You acknowledge and hereby acknowledge that copies of your data may remain accessible even after deletion on cached and archived pages or after a third party has made a copy/storage of your content.

Cookies and Similar Technologies

When you visit or access our Services, we authorize third parties to use web beacons, cookies, pixel tags, scripts, and other technologies and analytics services ("Tracking Technologies"). These Tracking Technologies may allow third parties to collect your information automatically in order to improve the browsing experience on our digital assets, to optimize their performance and to ensure a customized user experience, as well as for security and fraud prevention purposes.

To learn more about this, please read our cookie policy.

Category: The user is NOT affiliated with an advertising service

We will not share your email address or other personally identifiable information with any advertising company or advertising network without your consent.

Category: The user is connected to an advertising service, a campaign manager or to Facebook Ads

We may provide advertising, which may also be tailored to you, through our Services and our digital assets (including websites and applications that use our Services), such as: B. Ads based on your recent browsing behavior on websites, devices or browsers.

In order to serve these advertisements to you, we may use cookies and/or JavaScript and/or web beacons (including clear GIFs) and/or HTML5 local storage and/or other technologies. We may also use third parties such as B. Network Advertisers (i.e.  H. Third parties who serve ads based on your website visits) to serve targeted ads. Third-party ad network providers, advertisers, sponsors and/or website traffic measurement services may also use cookies and/or JavaScript and/or web beacons (including clear GIFs) and/or Flash cookies and/or other technologies to improve effectiveness measure your ads and customize ad content for you. These third party cookies and other technologies are governed by the specific privacy policy of the third party and not this one.

Where do we store the data?

Category: Always

Non-Personally Identifiable Information

Please note that our companies and our trusted partners and service providers are located around the world. For the purposes explained in this Privacy Policy, we store and process all non-personal data that we collect in different jurisdictions.

Category: User collects personal data

Personal Data

Personal information may be maintained, processed and stored in the United States, Ireland, South Korea, Taiwan, Israel and other jurisdictions to the extent required for the proper provision of our Services and/or by law (as further explained below).

How long is the data retained?

Category: Always

Please note that we retain the information we collect for as long as is necessary to provide our services, comply with our legal and contractual obligations to you, resolve disputes, and enforce our agreements.

We can correct, supplement or delete incorrect or incomplete data at any time at our own discretion.

How do we protect the data?

Category: Always

The hosting service for our digital assets provides us with the online platform through which we can offer our services to you. Your data may be stored through our hosting provider's data storage, databases and general applications. It stores your data on secure servers behind a firewall, and it offers secure HTTPS access to most areas of its services.

Category: User accepts payments/eCom

All payment options offered by us and our hosting provider for our digital assets comply with the regulations of the PCI-DSS (data security standard of the credit card industry) of the PCI Security Standards Council (council for security standards of the credit card industry). This is a collaboration between brands such as Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card data (including  a. physical, electronic and procedural measures) by our shop and the service providers.

Category: Always

Notwithstanding the measures and efforts taken by us and our hosting provider, we cannot and do not guarantee the absolute privacy or security of any information you upload, post or otherwise disclose to us or others.

For this reason, we would like to ask you to set strong passwords and, if possible, not to transmit to us or others confidential information, the disclosure of which you believe could cause serious or lasting harm to you. In addition, since email and instant messaging are not considered secure forms of communication, we ask that you do not share any confidential information through any of these communication channels.

How do we deal with minors?

Category: User does NOT collect data from minors

The Services are not intended for users who have not yet reached the legal age of majority. We will not knowingly collect information from children. If you are under the age of majority, you should not download or use the Services or provide any information to us.

We reserve the right to request proof of age at any time so that we can verify that minors are using our Services. In the event that we become aware that a minor is using our Services, we may block or block access to our Services for such users and we may delete any information we hold about that user. If you have reason to believe that a minor has provided us with information, please contact us as set out below.

Category: User collects data from minors

Children can use our services. However, if you want access to certain features, you may be required to provide certain information. Collection of some information (including information collected via cookies, web beacons and other similar technologies) may be automatic. If we knowingly collect, use or disclose any information collected from a child, we will provide notice and obtain parental consent in accordance with applicable law. We do not condition a child's participation in an online activity to the child providing more contact information than is reasonably necessary to participate in that activity. We only use the information we collect in connection with the services that the child has requested.

We may also use a parent's contact information to communicate about the child's activities on the Services. Parents can see information we have collected from their child, prohibit us from collecting any more information about their child, and request that all information we have collected be deleted from our records.

Please contact us to view, update or delete your child's information. To protect your child, we may ask you to provide proof of your identity. We can deny you access to the data if we believe that your identity is in question. Please note that certain data cannot be deleted due to other legal obligations.

Category: Always

We will only use your personal information for the purposes set out in the Privacy Policy and only when we are satisfied that:

• the use of your personal information is necessary to perform or enter into a contract (e.g. to provide you with the Services themselves or to provide customer or technical support);
• the use of your personal data is necessary to comply with a relevant legal or regulatory obligation, or
• the use of your personal information is necessary to support our legitimate business interests (provided that we do so at all times in a way that is proportionate and respects your privacy rights).

As an EU resident you can:

• request confirmation as to whether or not personal data concerning you is being processed and request access to your stored personal data and certain additional information;
• request to receive personal data that you have provided to us in a structured, commonly used and machine-readable format;
• request rectification of your personal data held by us;
• request the erasure of your personal data;
• object to our processing of your personal data;
• request the restriction of the processing of your personal data, or
• lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. If you have general questions about the personal information we collect and how we use it, please contact us as provided below.

In the course of providing the Services, we may transfer information across borders to affiliates or other third parties and from your country/jurisdiction to other countries/jurisdictions around the world. By using the Services, you consent to the transfer of your information outside of the EEA.

If you are a resident of the EEA, your personal data will only be transferred to locations outside the EEA where we are satisfied that an adequate or comparable level of protection of personal data is in place. We will take appropriate steps to ensure that we have appropriate contractual arrangements in place with our third parties to ensure that appropriate safeguards are in place to minimize the risk of unlawful use, alteration, destruction, loss or theft of your personal information and that such third parties will act in accordance with applicable laws at all times.

California Consumer Protection Law Rights

If you are using the Services as a California resident, you may have rights under the California Consumer Privacy Act ("CCPA") to request access to and deletion of your information.

To exercise your right to access and delete your data, please see below how to contact us.

Category: The website does not sell any data of its users

We do not sell users' personally identifiable information for the intent and purposes of the CCPA.

Category: Websites with a blog or forum

Users of the Services who are California residents and under the age of 18 may request and obtain removal of their posted content by emailing the address provided in the "Contact Us" section below. These requests must all be labeled "California Removal Request." All requests must include a description of the content you wish to remove and information sufficient to enable us to locate the material. We will not accept communications that are unidentified or improperly submitted, and we may not be able to respond if you do not provide sufficient information. Please note that your request does not ensure that the material will be completely or comprehensively deleted. For example, material you post may be republished or reposted by other users or third parties.

Updates or changes to the Privacy Policy

Category: Always

We may, in our sole discretion, revise this Privacy Policy from time to time, the version posted on the Website will always be current (see “As of Date” statement). We encourage you to periodically review this Privacy Policy for changes. If there are any significant changes, we will post a notice on our website. Your continued use of the Services after notification of changes has been made to our website constitutes your acknowledgment and acceptance of the changes to the Privacy Policy and your agreement to be bound by the terms of those changes.

Contact

Category: Always

If you have general questions about the Services or the information we collect about you and how we use it, please contact us at:

Name: Jonas Jonetzki

Address: Hopfensack 19, 20457 Hamburg

Email address: info@earlyreal.com

​

DISCLAIMER

The information contained herein is not a substitute for legal advice and you should not rely on it alone. Specific requirements related to legal terms and policies may differ from state to state and/or jurisdiction to jurisdiction. As set out in our Terms of Service, you are responsible for ensuring that your Services are legal under the law that applies to you and that you comply with them.

To ensure you are fully compliant with your legal obligations, we strongly encourage you to seek professional advice to better understand which requirements are specific to you

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