# PRIVACY POLICY

Last updated 2024-11-11

This Privacy Policy for Real Microsoft, LLC ("Real Microsoft", "we", "us", or "our"), describes how and why we might access, collect, store, and/or use your personal information when you use the askLyphe software (the "Service").

Reading this Privacy Policy will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Service.

## SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Policy, but you can find out more details about any of these topics by using the table of contents below to find the section you are looking for.

What personal information do we process? Usage of the Service in its current form requires the collection and processing of only the data you explicitly provide (such as but not limited to your username and email address), as well as your IP address which may be used for additional account safety. You may read more about this below.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not collect or process any information of this kind.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? Your information is used to provide you our Service, as well as to verify account ownership. We may use your provided information to communicate with you, for security and fraud prevention, and to comply with law. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? Searches are sent to the third-party search-engines which you have enabled on your account or per-search. Otherwise, your information will only be shared with a third party in the event that we are legally required to do so in order to comply with law.

How do we keep your information safe? We take information security seriously, and to the best of our efforts follow industry-standard practices and procedures to protect your information from both malicious third parties and malicious actors within Real Microsoft. However, no electronic transmission or information storage technology can be guaranteed to be 100% secure, and as such we cannot promise or guarantee that unauthorized parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is to contact us at devnull@voremicrocomputers.com via email. We will consider and act upon any request in accordance with applicable data protection laws.

## TABLE OF CONTENTS

- 1. WHAT INFORMATION DO WE COLLECT?
- 2. HOW DO WE PROCESS YOUR INFORMATION?
- 3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
- 4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
- 5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
- 6. HOW LONG DO WE KEEP YOUR INFORMATION?
- 7. HOW DO WE KEEP YOUR INFORMATION SAFE?
- 8. WHAT ARE YOUR PRIVACY RIGHTS?
- 9. CONTROLS FOR DO-NOT-TRACK FEATURES
- 10. DO WE MAKE UPDATES TO THIS POLICY?
- 11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
- 12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

## 1. WHAT INFORMATION DO WE COLLECT?

We collect personal information that you voluntarily provide to us when you register on the Service, or otherwise when you contact us.

The personal information may include the following:

- email addresses
- usernames
- passwords
- IP addresses

We do not collect or process "sensitive" information.

## 2. HOW DO WE PROCESS YOUR INFORMATION?

We process your information in order to provide you with the Service, and to protect your private information and security.

The information given to us is used to facilitate account creation and otherwise account management. We may also use the email address associated with your account in order to notify you of important account notices, legal information, or notices in relation to the Service.

## 3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

This paragraph applies to you if you are located in the EU or UK. The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your information. As such, we may rely on the following legal bases to process your personal information:

- Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You have the right to withdraw your consent at any time, and may do so by contacting us at devnull@voremicrocomputers.com
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

This paragraph applies to you if you are located in Canada. We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time, and may do so by contacting us at devnull@voremicrocomputers.com. In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.
- For investigations and fraud detection and prevention.
- For business transactions provided certain conditions are met.
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.
- For identifying injured, ill, or deceased persons and communicating with next of kin.
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse.
- If it is reasonable to expect collection and use with consent would compromise the availability or accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced.

## 4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

As one or more Third-Party search engine "backends" may be used for queries, these third-party services will receive only the necessary information to provide you with their results. This information should not consist of more than your search query.

Otherwise, we will only share your personal information with third parties in the event that we must do so to comply with law. In the event of a business transfer, merger, or acquisition, your data may be deleted from our databases unless consent for the transfer is given.

## 5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

Our servers are located in the United States. If you are accessing our Service from outside the United States, please be aware that your information may be transferred to, stored by, and processed by us in our facilities.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then the countries in which your data is stored may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law.

## 6. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

## 7. HOW DO WE KEEP YOUR INFORMATION SAFE?

We take information security seriously, and to the best of our efforts follow industry-standard practices and procedures to protect your information from both malicious third parties and malicious actors within Real Microsoft. However, no electronic transmission or information storage technology can be guaranteed to be 100% secure, and as such we cannot promise or guarantee that unauthorized parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

Although we will do our best to protect your personal information, transmission of personal information to and from our Service is at your own risk. You should only access the Service within a secure environment.

## 8. WHAT ARE YOUR PRIVACY RIGHTS?

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request, access, and obtain a copy of personal information; (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us at devnull@voremicrocomputers.com

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us via email at devnull@voremicrocomputers.com.

However, please note that this will not affect the lawfulness of processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you would at any time like to review or change the information in your account or terminate your account, please contact us at devnull@voremicrocomputers.com.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

## 9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.

We currently do not respond to DNT signals, as we feel that there is nothing extra that we could do to facilitate this request. We do not automatically monitor or collect any information from your usage of the Service except that which is required or deemed necessary to provide you with the Service, and any information that is required to be collected for normal functionality is not shared with any third-parties except in the rare cases specified in Section 4.

## 10. DO WE MAKE UPDATES TO THIS POLICY?

We may update this Privacy Policy from time to time, such as but not limited to the introduction of new features to our Service.

The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

## 11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have any questions or comments about this policy, you may email us at devnull@voremicrocomputers.com

## 12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please contact us at devnull@voremicrocomputers.com