Privacy Policy

1. Introduction

Evoreality Pvt. Ltd. (“EvoReality”, “we”, “us”, or “our”) is committed to protecting the privacy of everyone who visits our website and uses our services. We build AR/VR and game-based solutions to support healthy brain aging, including cognitive assessment and practice tools intended for individuals, their families and caregivers, and clinicians.

This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and the rights available to you. It is designed to comply with the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and other applicable laws of India.

By accessing our website, creating an account, or using our services, you acknowledge that you have read and understood this Policy. Where the law requires your consent, we will ask for it separately.

2. Scope of this Policy

This Policy applies to the EvoReality website at https://www.evoreality.in (the “Website”) and to the accounts and services you access through or in connection with it (together, the “Services”).

3. Who We Are (Data Fiduciary)

For the purposes of the DPDP Act, EvoReality is the Data Fiduciary responsible for your personal data. Our details are:

• Entity: Evoreality Pvt. Ltd.
• Registered address: 7, Narmada Complex, Old Cotton Market Road, Amravati – 444602, Maharashtra, India
• Email: team@evoreality.in
• Phone: +91-94051 04014

4. Information We Collect

We collect only the information we need to provide and improve our Services. This includes:

a) Information you provide directly

• Contact form: your first name, last name, email address, and the contents of your message.
• Account registration: the details you provide when signing up, such as your name, email address, and login credentials.

b) Information collected automatically

• Usage and performance data: your scores and progress within our games and cognitive-training activities.
• Device information: such as device model, operating system, app version, and similar technical identifiers.
• Usage analytics: information about how you interact with our Services, used to understand and improve performance and reliability.

c) Cognitive assessment information

Some of our tools involve cognitive assessment activities. Where standardised cognitive tests are administered, this is done under the guidance of a qualified medical professional. Assessment results and game-performance data may indicate aspects of cognitive functioning and are treated by us with heightened care, consistent with the sensitivity of such information.

We do not intentionally collect any personal data beyond what is described above through the Website.

5. How We Use Your Information

We use the personal data we collect to:

• Respond to enquiries and messages submitted through our contact form.
• Create and manage your account and provide access to our Services.
• Deliver, personalise, and maintain our games, assessment, and practice features.
• Measure and improve the performance, quality, and reliability of our Services.
• Support cognitive assessment and practice, where applicable and under appropriate professional guidance.
• Conduct research and develop new features (see Section 6).
• Comply with legal obligations and protect the rights, safety, and security of our users and EvoReality.

6. Use of Data for Research

EvoReality has a research foundation, and some data may be used to advance the science of brain health and cognitive assessment. Where data is used for research or publications, it is anonymised first, so that it can no longer reasonably be linked back to you. Anonymised data is not personal data and may be retained and used to further our research mission.

7. Consent and Legal Basis

Under the DPDP Act, we process your personal data on the basis of your consent, or for certain legitimate uses permitted by law. Before or at the time of collecting your personal data, we will provide a clear notice of what we collect and why. You may withdraw your consent at any time (see Section 11); withdrawing consent does not affect processing carried out before withdrawal, and may limit our ability to provide certain Services.

8. How We Share Your Information

We do not sell your personal data, and we do not share it for third-party advertising. We share personal data only in the limited circumstances below:

• Service providers (Data Processors): we use Google Firebase to provide infrastructure such as authentication, data storage, and analytics. These providers process data on our behalf and under our instructions.
• Clinicians and care providers: where you use our Services through a healthcare professional, relevant information may be shared with that professional as part of your care.
• Legal and safety: where required to comply with applicable law, legal process, or a lawful government request, or to protect the rights, safety, and security of users or EvoReality.
• Business transfers: in connection with a merger, acquisition, or reorganisation, subject to this Policy continuing to apply to your personal data.

9. Third-Party Services (Firebase)

We rely on Google Firebase for core infrastructure, which may include authentication, database and storage, and analytics. Firebase processes certain data (such as account identifiers, device information, and usage analytics) in order to provide these services to us. Your use of our Services is also subject to Google’s applicable terms and privacy practices. Our Website itself does not use third-party advertising or non-essential tracking.

10. Data Retention

We keep personal data only for as long as it is needed for the purposes described in this Policy, or for as long as your account remains active. When personal data is no longer required, we delete it or anonymise it.

Data used for research is anonymised and may be retained for up to 10 years to support our ongoing research into brain health and cognitive assessment. Because this data is anonymised, it can no longer be linked to you.

11. Your Rights

Subject to the DPDP Act, you have the following rights in relation to your personal data:

• Right to access: obtain a summary of the personal data we hold about you and how it is processed.
• Right to correction and updating: have inaccurate or incomplete data corrected, completed, or updated.
• Right to erasure: request deletion of your personal data where it is no longer required and no legal obligation requires us to keep it.
• Right to withdraw consent: withdraw your consent at any time, as easily as it was given.
• Right to grievance redressal: raise a complaint with us about how your data is handled (see Section 14).
• Right to nominate: nominate another individual to exercise your rights in the event of death or incapacity.

To exercise any of these rights, contact us at team@evoreality.in. We may need to verify your identity before acting on a request.

12. Children and Vulnerable Users

Our Services are not intended for children under the age of 18, and we do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us so we can take appropriate steps to remove it.

Some of our users may be individuals living with dementia or other conditions that affect capacity. Where a user is under legal guardianship, consent and the exercise of rights may be provided by their lawful guardian or authorised caregiver on their behalf.

13. Data Security

We take reasonable technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, and loss. These include access controls and reliance on established infrastructure providers such as Google Firebase. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. In the event of a personal data breach that is reportable under applicable law, we will notify the relevant authority and affected individuals as required.

14. Grievance Redressal and Contact

If you have any questions, requests, or complaints about this Policy or how we handle your personal data, you can contact our grievance contact:

• Email: team@evoreality.in
• Address: Evoreality Pvt. Ltd., 7 Narmada Complex, Old Cotton Market Road, Amravati – 444602, Maharashtra, India

We will acknowledge and respond to your request within the timelines required by applicable law. If you are not satisfied with our response, you may have the right to raise the matter with the Data Protection Board of India.

15. Users Outside India

Our Services are currently intended for users in India, and your data is handled in accordance with Indian law. If you access our Services from outside India, you do so on your own initiative and are responsible for compliance with local laws. If we begin offering Services to users in other jurisdictions, we will update this Policy to reflect any additional obligations that apply.

16. Changes to This Policy

We may update this Policy from time to time to reflect changes in our Services, technology, or legal requirements. When we make material changes, we will update the “Last updated” date above and, where appropriate, notify you. We encourage you to review this Policy periodically.