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Last Updated: October 06, 2025

This Privacy Policy (“Policy”) is incorporated by reference into the Reality Network Terms of Use (“TOU”). All capitalized terms used here but not defined have the meanings set forth in the TOU. In the event of any conflict between this Policy and the TOU, the TOU controls.

1. INTRODUCTION

1.1 Purpose

This Policy explains how Rule 110, Inc. (“we,” “us,” or “our”) collects, uses, shares, and protects personal data in connection with the “Reality Network,” the “Portal Software,” the “SDK,” and the “APIs” (collectively, the “Services”).

1.2 Our Role in the Network

Rule 110, Inc. builds and maintains the protocol code for the Reality Network and operates some nodes on the Network (“Controlled Nodes”). However, the vast majority of Reality Network nodes are operated by independent third parties (“Independent Operators”) over whom we have no control.

By participating in the Network or using our Services, you acknowledge that data managed by Independent Operators (or placed on-chain by you or others) lies beyond our oversight and control. Please read this Policy carefully to understand what data we handle, and what remains outside our responsibility.

2. SCOPE & APPLICABILITY

2.1 Data Under Our Control

This Policy applies to personal data that Rule 110, Inc. directly collects and processes, such as:

  • Data stored or processed by the Portal Software (including basic logs or analytics).
  • Data collected via our Controlled Nodes (the subset of nodes we run).
  • Information you provide directly to us (e.g., support requests, newsletter sign-ups).

2.2 Data Outside Our Control

Many Reality Network nodes are beyond our control, and participants may deploy rApps, store data off-chain, or broadcast transactions. We do not control how Independent Operators configure their nodes, use logs, or store rApp data. We disclaim liability for data handling on nodes we do not operate.

Further, the Reality Network’s blockchain may record account balances and wallet addresses (and possibly other data if participants embed it). Once such data is on-chain, it is immutable and generally viewable by participants or block explorers.

2.3 Incorporation by Reference

All disclaimers, liability limitations, and relevant definitions in the TOU apply to this Policy. By using the Services, you consent to our collection and processing of personal data in accordance with this Policy. If you do not agree, discontinue use immediately.

3. DATA WE COLLECT

3.1 Data You Provide Voluntarily

We may collect personal data (such as your name or email address) if you:

  • Contact Us for Support: Submitting a message through our help desk or emailing us.
  • Opt In for Updates: Signing up for newsletters or product announcements.
  • Participate in Feedback or Beta Programs: Offering suggestions or bug reports.
  • Community feedback, surveys, or analytics opt-ins.

3.2 Technical & Usage Data

When you interact with the Portal Software, SDK, or APIs, we may automatically collect:

  • IP addresses, device/browser types, logs and analytics, timestamps, and pages accessed for security and troubleshooting.
  • Cookies or similar technologies (where lawful) to manage session state or gather aggregated analytics.

We do not use these for targeted advertising nor do we sell your data. Aggregated analytics for Network improvements (e.g., resource usage patterns).

3.3 Data Collected by Our Controlled Nodes

Our Controlled Nodes may store additional logs about consensus participation, resource usage, or node performance. This can include IP addresses of peers, timestamps of connections, or certain transaction metadata (e.g., wallet addresses engaging with that node).

We do not, however, intentionally store on-chain data in a human-readable format. Where feasible, personal data is hashed or otherwise obfuscated. Nevertheless, any data that is broadcast to the Reality Network’s ledger may be accessible to all nodes in the Network.

4. DATA ON THE REALITY NETWORK

4.1 Account Balances & Wallet Addresses

The Reality Network ledger primarily records:

  • Account/wallet addresses: Typically strings used to identify participants.
  • Account balances: E.g., token amounts tied to a given wallet address.

These addresses and balances are viewable by any participant or third party monitoring the blockchain (e.g., via an explorer). If an address can be linked to your identity, it may be considered personal data under regulations like GDPR or CCPA.

4.2 Hashing & Zero-Knowledge Proofs

The Network uses hashing and/or zero-knowledge proofs (ZKPs) to verify the integrity of data and computations without revealing the underlying data in plaintext.

  • Hashing: Transforms data into a fixed “fingerprint” to confirm authenticity, while making reversal of the original data highly improbable.
  • ZKPs: Permit one party to prove a statement (e.g., a valid transaction) without disclosing confidential details.

Caution: While these cryptographic techniques enhance privacy, they do not prevent you or third parties from placing other data on-chain. If personal data is embedded on-chain in any form, it may be replicated irreversibly.

4.3 No Guaranteed Absence of Personal Data

Although the Network is designed to store only balances, addresses, and cryptographic verifications, users (or rApps) could still embed arbitrary data in a transaction. We strongly discourage inserting personal identifiers or sensitive content on-chain. Once on-chain, it cannot be deleted or altered by any single party.

4.4 Liability Disclaimer

Beyond the Controlled Nodes, we do not control Independent Operators, rApps, or how they handle logs or data. We disclaim liability for any personal information that becomes visible or stored on-chain. You assume full responsibility for any data you choose to broadcast on the Network, as stated in the TOU.

5. HOW WE USE & SHARE DATA WE CONTROL

5.1 Service Provision & Improvements

We use the data we collect—like IP logs, device info, or feedback—to operate, maintain, and improve the Network, the Portal Software, SDKs, and APIs. For instance, logs help us debug errors or optimize system performance. Using analytics/feedback for community engagement and enhancements.

5.2 Communications

If you provide contact details (e.g., email), we may send:

  • Service Updates: Notices about key changes to the Portal or protocol.
  • Security Alerts: Critical advisories if we suspect unauthorized activity.
  • Newsletters (Opt-In): Marketing or product updates, which you can unsubscribe from at any time.

5.3 Legal Requirements & Security

We may disclose personal data if required by law (e.g., a lawful subpoena) or if necessary to:

  • Enforce our agreements or investigate potential violations of the TOU or this Policy.
  • Detect or prevent security incidents, fraud, or other malicious activities.
  • Protect the rights, property, or safety of our users, staff, or the public.

5.4 Service Providers

We may engage third-party vendors for hosting, analytics, or communications. These providers process personal data only on our behalf and under strict confidentiality obligations. We do not sell or rent personal data to third parties.

6. INTERNATIONAL TRANSFERS & NODE LOCATIONS

6.1 Data Transfers

Rule 110, Inc. may store or process personal data on servers located in various jurisdictions. Where required by law, we apply standard contractual clauses or other approved safeguards for international data transfers.

6.2 Global Distribution in the Reality Network

Any data placed on-chain can be copied to nodes worldwide. Even data within our Controlled Nodes may be transmitted among Independent Operators as part of consensus or transaction propagation. Once broadcast, it may be out of our practical reach for modification or deletion.

7. DATA SECURITY

7.1 Measures Taken

We implement industry-standard security measures—such as encryption in transit, limited staff access, and routine audits—to protect personal data on our own systems and Controlled Nodes.

7.2 User Responsibilities

You are responsible for:

  • Safeguarding your wallet keys, account credentials, or tokens.
  • Verifying any rApp or Node Operator’s reputation before sending sensitive info.
  • Complying with the TOU and refraining from embedding personal data on-chain.

7.3 No Absolute Guarantee

Although we strive to protect data under our control, no security system is infallible, and data on the Reality Network is inherently decentralized. Any data breach or misuse by Independent Operators is outside our direct control.

8. CHILDREN’S PRIVACY

8.1 Not Directed to Minors

As stated in the TOU, our Services are not intended for individuals under the age specified by law (e.g., under 16 or 13, depending on jurisdiction). We do not knowingly collect personal data from minors. If we discover we have unintentionally collected such data, we will delete it from our own systems. However, we cannot remove anything already placed on the blockchain.

9. YOUR RIGHTS & CHOICES

9.1 Data Subject Rights

Depending on your jurisdiction, you may have rights such as:

  • Access & Correction: Requesting a copy of or corrections to your personal data.
  • Deletion: Asking us to remove your personal data from our systems.
  • Objection / Restriction: Restricting certain processing where lawful.
  • Portability: Obtaining a machine-readable copy of data you provided.

To exercise these rights for data we control, contact us per Section 12.

9.2 Limitations in a Decentralized Context

If personal data is on-chain or stored by Independent Operators, we cannot delete or alter it. The Reality Network is immutable, and we lack authority over third-party nodes or rApps.

9.3 CCPA & ‘Do Not Sell’

For California residents, we do not “sell” personal data as defined by the CCPA. You may contact us regarding any other CCPA rights (like requests to know or delete), and we will address them consistent with the limitations above.

9.4 GDPR & Lawful Bases

For EU/EEA/UK residents, we rely on contractual necessity, legitimate interests, or consent (where required) to process personal data. We practice data minimization and strive to ensure no personal data is placed on-chain except for pseudonymous references (like wallet addresses). We will respond to GDPR requests within legal deadlines but may be limited by the blockchain’s immutability.

10. DISCLAIMER & LIMITATION OF LIABILITY

10.1 Nodes Outside Our Control

We do not warrant or represent that Independent Operators or rApps will follow any particular privacy practices. By using the Reality Network, you acknowledge that any data stored on nodes we do not control is beyond our oversight. Consequently, we disclaim liability for the privacy, security, or retention of such data, as further detailed in the TOU.

10.2 On-Chain Immutability

Any personal data broadcast on-chain may be permanently replicated in the ledger. We cannot promise compliance with data erasure requests if the data was placed on-chain.

10.3 Assumption of Risk

You assume all risk for interactions with the Reality Network, including any potential correlation of your wallet address with your identity, or misuse by third parties of data that you or others publish on-chain.

11. CHANGES TO THIS POLICY

We may periodically update this Policy to reflect new practices, legal requirements, or technical changes. The “Last Updated” date at the top indicates when revisions were made. If we make substantial changes, we may notify you via the Portal Software or another method. Your continued use of the Services after any revised Policy becomes effective signifies your acceptance of those changes.

12. CONTACT US

If you have questions, requests, or concerns regarding this Privacy Policy or your personal data, please reach out to:

Email: [email protected]

Mail: Rule 110, Inc. – Brian O’Beirne, Privacy Officer

We will make reasonable efforts to address your inquiry in a timely manner.

For more details on disclaimers, liability limitations, and your responsibilities, please see the Terms of Use. If you do not accept our data practices or disclaimers, your sole recourse is to cease using the Services and avoid interacting with the Reality Network.

By using our Portal, SDK, APIs, or interacting with Controlled Nodes, you acknowledge and accept this Privacy Policy. If you do not agree, you must discontinue use of the Services and the Reality Network in accordance with the TOU.