Effective Date: October 10, 2025
ExitReality Inc. (“ExitReality,” “we,” “our,” or “us”) is committed to protecting the privacy of individuals whose personal data we process. This privacy policy describes how we collect, use, and disclose personal data transferred to the United States from the European Union (“EU”), the United Kingdom (“UK,” including Gibraltar), and Switzerland under the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).
1. DPF Participation and Commitment
ExitReality complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. ExitReality has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. ExitReality has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.
If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.
To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit: https://www.dataprivacyframework.gov/
2. Scope of Data Covered
This policy applies to non-human resources (non-HR) personal data that ExitReality receives in the United States from the EU, UK, and Switzerland.
ExitReality’s services allow customers to create and manage online events and training sessions. We may receive and process the following types of personal data from users and participants:
- Name
- Email address
- Organization or company name (optional)
- Information submitted during event registration or participation
ExitReality does not receive or process HR (employment-related) data under the DPF.
3. Purpose of Data Processing
ExitReality processes personal data for the following purposes:
- To provide, operate, and manage our platform and related services
- To register users for events or training sessions
- To communicate with users about their accounts or participation
- To provide customer support and technical assistance
- To improve and maintain our services
4. Choices and Means to Limit Use and Disclosure
Individuals may request to limit the use or disclosure of their personal data by contacting us at: [email protected]
For example, individuals may:
- Opt out of receiving non-essential communications
- Request deletion or restriction of their personal data where applicable
- Withdraw consent for data processing where consent is the lawful basis
5. Right of Access
Individuals have the right to access the personal data that ExitReality holds about them. Upon request, ExitReality will provide individuals with access to their personal data and allow them to correct, amend, or delete that information where it is inaccurate or has been processed in violation of the DPF Principles, subject to any applicable legal limitations.
6. Data Sharing and Onward Transfer
ExitReality may share personal data with third-party service providers who perform services on our behalf, such as:
- Cloud hosting and infrastructure providers
- Email and communication tools
- Customer support tools
We require all third parties to process personal data only for the purposes for which it was provided and in accordance with the DPF Principles.
We remain responsible for all personal data received under the DPF and that we subsequently transfer to third parties acting as agents on our behalf if they process personal information in a manner inconsistent with the DPF Principles.
7. Public Authority Disclosure
ExitReality may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
8. Independent Recourse Mechanisms (IRM)
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, ExitReality commits to cooperate and comply respectively with the advice of:
- the EU Data Protection Authorities (DPAs),
- the UK Information Commissioner’s Office (ICO), and
- the Swiss Federal Data Protection and Information Commissioner (FDPIC)
with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.
Individuals may contact their respective DPA, ICO, or FDPIC free of charge for complaint resolution.
9. Binding Arbitration
Under certain circumstances, individuals may invoke binding arbitration for complaints regarding DPF compliance when other dispute resolution procedures have been exhausted. ExitReality is obligated to arbitrate claims and follow the terms as set forth in Annex I of the DPF Principles.
More information about this process is available through the DPF Program website: https://www.dataprivacyframework.gov/
10. Enforcement and Oversight
ExitReality is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC) with respect to its compliance with the DPF Principles.
11. Contact Information
If you have any questions or complaints about our DPF participation or data handling practices, please contact us at:
Email: [email protected]
Mail: ExitReality, Inc., Attn: Legal, 1 E. Washington St, Ste 1600, Phoenix, AZ 85004, USA
12. Updates to This Policy
This privacy policy may be updated periodically to reflect changes in our practices or to comply with updated DPF requirements. Updated versions will include a new effective date and will be posted on our website.