This privacy policy has been drawn up in accordance with the requirements of the Federal Law of July 27, 2006. № 152 "On personal data" and determines the procedure for processing personal data and measures to ensure the security of personal data of LLC "Inreal" (hereinafter - the Company).

1.1. The Company provides a software package, which includes current and any further development, upgrade and version of the program for the organization and conduct virtual meetings, a private app for user devices, also website located at https://inreal.online (hereinafter - Program), where any able-bodied person using the App can create and manage virtual space (hereinafter - the User).
1.2. In this privacy Policy we explain how we process data of Users (hereinafter - the Personal data).
1.3. This Policy (hereinafter referred to as the Policy) does not apply to relations arising from:

• organization of storage, acquisition, accounting and use of documents containing personal data that have the status of archival documents in accordance with the legislation on archival affairs in the Montenegro,
• processing of Personal Data classified in accordance with the established procedure as information constituting a state secret.

1.4. This Policy is a publicly available document and is published on the Company's official website on the Internet.
1.5. This Policy may be updated from time to time to reflect changes in data processing methods or otherwise. We recommend that you periodically check the relevance of this Policy.
1.6. By continuing to use the Program, after changing the Policy, you confirm your consent to the changes made.

2.1. We may collect the following personal data:

• Personal data that you provide to us when filling out information fields in the Program, including when filling out a contact form;
• Personal data and other information contained in the messages you send to us;
• technical data that is automatically transmitted by the device with which you use our Program, including the technical characteristics of the device, IP address, information stored in cookies that were sent to your device, browser information, date and time of access to the Program and other similar information. For more information about the use of cookies, see the section "Cookie Policy";
• in addition, when using the Application, you will need to process and save the following data:
• voice data that when using Application is transmitted and processed through our secure servers with a secure connection for voice communication with other users. Voice data can be recorded at your request. Voice communication can be disabled in the App;
• VR/AR tracking data, including the location of your avatar in virtual space. Tracking data is transmitted and processed only through our secure servers with a secure connection. The data can be recorded at your request in the same way as your voice data. Positional and voice data can in some cases be stored and processed together.

2.2. We may collect your Personal Data in various ways, including when you register and use the Application or fill out a form on the website..

3.1. We use various technologies to collect and store analytics data and other information when you visit our Application, including cookies, pixel tags and web beacons.
3.2. Cookies are small text files that are sent and stored on your device, which allows us to identify visitors to our Program and facilitate the use of the Program, as well as collect general information about our visitors.
3.3. A web beacon is a technology that allows you to identify readers of websites and emails, for example, to determine whether an email has been read.
3.4. Collecting and storing cookies, pixel tags and web beacons helps us to improve the Application and better serve our Users. Cookies will not harm your device or file. We use cookies to customize our Program according to your interests.
3.5. You can configure your web browser so that it refuses cookies or warns about sending cookies. Please note that some parts of our Application may not work properly if the use of cookies is denied.

4.1. We may process your Personal Data solely for use for the following purposes:

• your identification, after registration in the Program, to provide access to the Program;
• establishing feedback with you, including sending notifications, requests regarding the use of the Program, processing your requests and requests;
• determining your location to ensure security, fraud prevention;
• confirmation of the accuracy and completeness of the Personal Data provided by you;
• processing and receiving payments, challenging the payment, determining the right to receive a credit line by you;
• providing you with effective customer and technical support in case of problems related to the use of the Program;
• providing you with your consent, Program updates, special offers, pricing information, newsletters and other information on behalf of the Company via e-mail, SMS and other types of mailings;
• carrying out advertising activities with your consent.

4.2. We do not publish your Personal Data in publicly available sources. We do not make decisions affecting your rights and legitimate interests based solely on automated processing of Personal Data.

5.1. Personal Data processing – any legal action (operation) or set of actions (operations) performed with or without the use of automation tools with Personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of Personal data.
5.2. We process your Personal Data only if they are filled in and/or sent through special forms located in the Program. By filling out the appropriate forms and/or submitting your Personal Data, you express your consent to this Policy.
5.3. The security and safety of Personal Data processed by the Company is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
determining your location to ensure security, fraud prevention;

• The Company ensures the safety of Personal Data and takes all possible measures to exclude access to the Personal Data of unauthorized persons;;
• Under no circumstances will personal data be transferred to third parties, except in cases related to the fulfillment of state obligations;
• in case of inaccuracies in Personal data, you can update them yourself by sending a notification to the Company's email address info@inreal.online marked "Updating of personal data";
• the period of processing of Personal Data is unlimited. You can withdraw your consent to the processing of Personal Data at any time by sending a notification to the Company via e-mail to the Company's e-mail address info@inreal.online marked "Withdrawal of consent to the processing of Personal data".

5.4. We may transfer the Personal Data stored by us:

• law enforcement and other state and regulatory bodies, as well as other third-party organizations and persons in accordance with the requirements of current legislation and regulations;
• to third-party organizations authorized to request the disclosure of Personal Data in order to verify our compliance with the requirements of current legislation and regulations or for the purpose of investigating an alleged crime, as well as establishing, exercising or protecting legal rights.

5.5. We respond to requests for disclosure of Personal Data only in cases where we must do so in accordance with the requirements of current legislation and regulations.

6.1. Cross-border transfer of Personal data – transfer of Personal data to the territory of a foreign state to the authority of a foreign state, foreign natural or foreign legal entity.
6.2. The company prior to the implementation of cross-border transfer of Personal data is required to ensure that the foreign state in whose territory it is supposed to transfer Personal data provides reliable protection of the rights of subjects of Personal data.
6.3. The cross-border transfer of Personal Data on the territory of foreign states that do not meet the above requirements can be carried out only if you have your written consent to the cross-border transfer of your Personal Data and/or the execution of the contract to which you are a party.

7.1. Termination of Personal Data processing – any actions as a result of which Personal Data is permanently destroyed with the impossibility of further restoration of the content of Personal Data in the Personal data information system and (or) as a result of which the material carriers of Personal Data are destroyed.
7.2. We stop processing your Personal Data:

• upon the occurrence of the conditions for the termination of the processing of Personal Data or after the expiration of the established deadlines;
• upon reaching the goals of their processing or in case of loss of the need to achieve these goals;
• at your request, if the processed Personal Data is illegally obtained or is not necessary for the stated purpose of processing;
• in case of detection of unlawful processing of Personal Data, if it is impossible to ensure the legality of processing;
• upon expiration of the validity period of your consent to the processing of Personal Data or in case of withdrawal of such consent by you, if there are no other legal grounds for the processing of Personal Data provided for by the legislation of the Montenegro;
• in case of liquidation of the Company.

7.3. You can also ask us to delete your Personal Data from our systems by sending your request by email info@inreal.online. We will fulfill such a request if we have no legal grounds not to delete the data.

8.1. Our Program may contain links to third-party websites and services that we do not control. We are not responsible for the security or confidentiality of any information collected by third-party sites or services.

You can get any clarifications on issues of interest regarding the processing of your Personal data by contacting the Company via e-mail info@inreal.online.