This Privacy Policy explains how Even Realities collects, uses, retains, discloses, and transfers personal data in connection with the Even Hub Developer Platform, including when you access the Platform as a guest or submit information without registering for or signing in to an account, the Even Realities Developer Network (“ERDN”), developer support, and other activities within the Even Hub developer ecosystem. It also explains the privacy rights and choices available to you.
This Policy does not apply to the independent processing of Even Hub end-user personal data through a Developer’s Plug-in. In relation to such processing, the Developer generally acts as an independent controller under the Even Hub Developer Platform Data Processing Agreement and is responsible for providing end users with its own privacy policy and complying with applicable data-protection laws.
In this Policy, "Even Realities," "we," "us," or "our" means:
- Even Realities GmbH, Friedrichstraße 79, 10117 Berlin, Germany, if you access the services from within the European Economic Area ("EEA"); or
- Hong Kong Even Realities Limited, Room 29D, 8/F, On Cheong Factory Building, No. 19 Tai Yip Street, Kwun Tong, Hong Kong, if you access the services from outside the EEA.
We may update this Policy from time to time. If a change materially affects how we use your personal data or your rights, we will provide notice through our website, the Platform, email, or another appropriate channel and will obtain consent where required by law.
1. What Personal Data Do We Collect?
We process the following information as needed to review your application, take steps at your request, perform our agreement with you, comply with applicable law, protect the Platform and our legitimate interests, or with your consent where required.
Even Hub account and Plug-in information. We collect your name, email address, country or region, account and authentication records, Plug-in details and files, permission and API configurations, review communications, and publication status. We use this information to create and secure your account and to review, publish, and manage Plug-ins. It is retained while the account or Plug-in relationship remains active and for the shortest period needed afterward for security, traceability, disputes, or legal obligations.
Developer profile information. We collect information about your ownership of Even Glasses, experience developing for G2 and other smart or XR devices, software-development history, and any website, GitHub, LinkedIn, or other social links you provide. We use this information to understand your experience, verify your work, and match you with appropriate programs and support. Profile links are optional and are deleted or de-identified when no longer needed.
ERDN application information. We collect your name, email address, applicant type, organization, role, country, region, and city to identify and contact you and assess program eligibility. Fields marked as required must be provided to submit an application. We retain an application through the assessment process and for the shortest additional period needed for review, disputes, audits, or legal obligations.
Security, compliance, and support information. We collect IP addresses, browser and operating-system types, access and API logs, error records, security signals, support communications, compliance materials, audit records, and incident reports. We use this information to protect and troubleshoot the Platform, respond to requests, review compliance, and investigate incidents. We retain it only for as long as needed for those purposes and then delete or anonymize it.
Program, event, and fulfillment information. If you participate in an event or are selected for a program, we may collect registration and communication records and, where needed, verification, agreement, recipient, address, telephone, and delivery information. We use this information to operate developer programs, provide benefits, and deliver devices. Event participation and marketing are optional; fulfillment details are required only after selection. We retain the information for the event or program and for any applicable delivery, warranty, finance, tax, dispute, opt-out, or legal period.
Do not include passwords, government identification numbers, payment information, health information, precise location, third-party confidential materials, or personal data you are not authorized to provide in a Pitch, Plug-in description, support ticket, other free-text field, or attachment. If additional personal data is genuinely necessary to process an application or security incident, we will provide further information about the purpose, necessity, and retention rules at the time of collection.
2. How Do We Use Your Personal Data?
We use your personal data only where permitted by applicable law. Depending on the circumstances, we process it because we need to perform an agreement with you or take steps at your request, you have given us consent, the processing is necessary to comply with a legal obligation, or the processing supports our legitimate interests and does not override your rights.
We use your personal data to:
- create, authenticate, secure, and manage your Even Hub Developer account;
- provide development tools and APIs and review, publish, update, or remove Plug-ins;
- receive, review, and administer ERDN and other developer program applications;
- evaluate your developer background and App Pitch and communicate application decisions;
- provide developer support and organize events, roundtables, and community activities;
- verify eligibility and deliver program benefits or devices to selected Developers;
- detect, investigate, and prevent fraud, abuse, security incidents, and violations of our terms;
- conduct security and compliance reviews and respond to legal claims, audits, and regulatory requirements; and
- send optional developer news and promotional communications where you have consented or where otherwise permitted by law.
If we need to use your personal data for a materially different purpose, we will provide additional notice and obtain consent where required.
3. Service Providers, Affiliates, and Other Recipients
We disclose personal data only to the extent necessary for a defined purpose and use contracts, access controls, and security requirements to limit the recipient's processing.
Airtable. Formagrid Inc., doing business as Airtable, hosts and transmits the ERDN application form and attachments. When you access, complete, or submit the form, Airtable processes the form fields, uploaded Pitch files, and technical data needed to provide the service. Depending on the applicable Airtable configuration and its subprocessors, this information may be processed or stored in the United States or other jurisdictions.
Even Realities affiliates and authorized teams. Relevant teams may access identity and contact details, application and background materials, account and Plug-in information, and support or review records to assess applications, administer developer accounts and programs, provide support, and conduct security and compliance reviews.
Technology and support providers. Cloud-hosting, identity-authentication, security-monitoring, email, and customer-support providers may process account information, contact details, platform logs, support tickets, and necessary technical data to operate and protect the Platform.
Event and community providers. If you register for a developer event, roundtable, community, or video conference, the relevant provider may process your name, email address, account identifier, registration information, and event interactions.
Logistics providers. If you are selected to receive a device, logistics and fulfillment providers may process the recipient name, address, telephone number, shipped item, and delivery status.
Professional advisers and authorities. Advisers, auditors, regulators, law-enforcement authorities, or courts may receive information relevant to an audit, legal obligation, dispute, or protection of legitimate rights and interests.
We do not make an ERDN application or Pitch submitted only through the ERDN application form public merely because it is submitted. We use such materials to evaluate applications and administer the relevant program. If we wish to feature an applicant's name, profile image, work, story, application, or Pitch publicly outside the rights granted under any applicable terms, we will provide additional notice and obtain authorization where required.
Developer Content, published Plug-ins, and Developer names, trademarks, or logos submitted through or used in connection with the Even Hub Developer Platform are governed by the Even Hub Developer Platform Terms of Service and any other applicable terms. To the extent permitted by those terms, we may host, review, display, distribute, use, or otherwise process those materials to operate, provide, improve, market, or promote the Platform and other Even Realities products or services. This Policy does not expand or limit the licenses or other rights granted under those terms.
If a merger, acquisition, reorganization, asset sale, or business transfer occurs, personal data may be transferred as part of the transaction. We will require the recipient to continue protecting the personal data under this Policy and applicable law and will notify you where required.
4. International and Cross-Border Transfers
The Even Hub Developer Platform is hosted on servers located in the Netherlands. If you are located outside the Netherlands, your personal data may therefore be transferred to and processed in the Netherlands.
We also use affiliates and third-party service providers whose personnel, systems, or subprocessors may be located in other countries. For example, the ERDN application form is provided through Airtable, and form fields, Pitch attachments, and related technical data may be processed or stored in the United States or other jurisdictions, depending on the applicable Airtable configuration and subprocessors. As a result, your personal data may be transferred from the country or region where you live to the Netherlands and to other locations in which our affiliates or service providers operate. Those locations may have data-protection laws that differ from the laws in your country or region.
For cross-border transfers, we apply safeguards required by applicable law, including, where applicable, standard contractual clauses, transfer-risk assessments, access restrictions, encryption or de-identification, and mechanisms that allow you to exercise your privacy rights. For transfers subject to the personal information protection laws of the People's Republic of China, where applicable, we will separately inform you of the overseas recipient, processing purpose, types of personal information, and method for exercising rights; obtain separate consent; and complete any legally required assessment, certification, contract, or filing process. For transfers subject to European data-protection law, we rely on an adequacy decision, the European Commission's Standard Contractual Clauses, or another lawful transfer mechanism.
5. How Do We Protect Personal Data?
We have implemented and maintain appropriate technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, as well as against other unlawful or unauthorized forms of processing. Such measures include, as appropriate, encryption of personal data in transit and at rest, role-based and least-privilege access controls, periodic reviews of user accounts and access permissions, system logging and security monitoring, vendor-security management, confidentiality obligations for personnel, security testing, and documented incident-response procedures.
Although we take reasonable measures to safeguard personal data, no method of transmission over the Internet or method of electronic storage is completely secure. In the event of a personal data breach, we will promptly investigate, contain, mitigate, and remediate the incident. Where required by applicable law, we will notify affected individuals and the competent supervisory or regulatory authorities within the applicable time limits. Such notice will include, as appropriate, information concerning the nature of the breach, its likely consequences, the measures taken or proposed to address it, steps that affected individuals may take to protect themselves, and the relevant contact details.
6. Retention and Deletion
We retain personal data only for as long as reasonably necessary to fulfill the purposes for which it was collected, including administering applications and developer programs, providing and securing the Platform, maintaining business and compliance records, resolving disputes, enforcing our agreements, and satisfying applicable legal and regulatory obligations. Retention periods may vary depending on the category of personal data and the circumstances of the processing. In determining the appropriate retention period, we consider the nature, volume, and sensitivity of the personal data; the purposes and risks of the processing; the duration of the relevant account, program, or contractual relationship; applicable limitation periods; and our contractual, legal, and regulatory obligations.
Upon expiration of the applicable retention period, we will securely delete or anonymize the personal data in accordance with our data-retention and deletion procedures. Where continued retention is required or permitted by applicable law, or is reasonably necessary for the establishment, exercise, or defense of legal claims, compliance, audit, fraud-prevention, or security purposes, access to the personal data will be restricted and the data will be processed only for the relevant retention purpose. Personal data contained in backup systems will be removed or rendered inaccessible in accordance with our backup-retention cycle and secure-deletion procedures.
7. What Are Your Data Subject Rights and Choices?
Subject to applicable law and depending on where you live, you may have certain rights regarding your personal data.
Access. You may request information about the personal data we process about you, including the categories of data, the purposes for which we use it, and the categories of recipients to whom it is disclosed. You may also request a copy of your personal data.
Correction. You may correct certain account information through available account settings. You may also ask us to correct inaccurate or incomplete personal data.
Portability. Where applicable, you may request personal data you provided to us in a structured, commonly used, and machine-readable format, or ask us to transmit it to another organization where technically feasible.
Deletion. You may request deletion of your developer account, application, or other personal data. We may retain limited information where required by law or reasonably necessary for security, disputes, or other lawful purposes. If we cannot delete certain information, we will explain why.
Direct marketing. You may unsubscribe from promotional emails or ask us to stop using your personal data for direct marketing. This will not prevent us from sending essential service, security, or account notices.
Withdrawal of consent. Where we rely on your consent, you may withdraw it at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.
Objection to or restriction of processing. Where applicable, you may object to processing based on our legitimate interests or ask us to restrict processing, including while we verify the accuracy of information or consider an objection. We may continue processing where we have overriding lawful grounds and will explain when this applies.
Other rights and complaints. Depending on your jurisdiction, you may have additional rights and may lodge a complaint with a competent data-protection authority.
To exercise a right, ask a privacy question, or submit a complaint, you could contact us in accordance with Section 8 of this Policy. Please describe your request and identify the relevant account, application, program, or processing activity so that we can respond appropriately. We may ask for information reasonably necessary to verify your identity, locate the relevant records, and protect your account and other individuals' personal data. If you submit a request on another person's behalf, we may ask for evidence that you are authorized to act for that person. We will respond within the period required by applicable law and will explain any lawful basis for refusing or limiting a request.
8. How to Contact Us
For more information about your privacy rights or how we process your personal data, contact us using the information below.
If you access the services from within the EEA:
Controller: Even Realities GmbH
Address: Friedrichstraße 79, 10117 Berlin, Germany
If you access the services from outside the EEA:
Controller: Hong Kong Even Realities Limited
Address: Room 29D, 8/F, On Cheong Factory Building, No. 19 Tai Yip Street, Kwun Tong, Hong Kong
Website: https://www.evenrealities.com/
Phone: +49 30 837 90777
Support: support@evenrealities.com
Data Protection Officer: privacy@evenrealities.com
We have appointed Prighter Group and its local partners as our privacy representative and point of contact in the following regions:
- United Kingdom; and
- Switzerland.
Prighter provides a channel through which you may exercise applicable privacy rights, including access and deletion requests. To contact us through Prighter, visit https://app.prighter.com/portal/17286675431.
9. Updates to This Policy
We may update this Policy to reflect changes in Platform functions, processing activities, vendors, laws, or regulatory requirements. If a change materially affects your rights, we will provide notice appropriate to the change through the Platform, a pop-up notice, email, or another prominent method. We will obtain consent again where required by law.
The current version will remain available through the Even Hub Developer Platform, the privacy link in the ERDN form, or the Even Support Center. Historical versions will remain available through an accessible webpage or archive. The publication page will clearly display the effective date and the date of the most recent update.