Research Program Privacy Policy

Last updated: 2nd June 2026

This Privacy Policy describes how RealityMine Limited and its subsidiaries (“RealityMine”) (“we,” “us” or “our”) process personal information that we collect from respondents who agree to participate in a SS Holdings Group, LLC d/b/a Sago (“Sago”) research program, panel, or study (a “Research Program”) that involves downloading and installing to their mobile device, tablet device, computer, or other personal device a software application that monitors and reports to us their online activities (the “Application”) (collectively, the “Service”). RealityMine and Sago (our “Panel Partner”) do not process personal information jointly.

See the U.S. State Privacy Rights Notice at Collection section of this Privacy Policy for additional information if you are a U.S. resident.

This Privacy Policy does not apply to data collected through RealityMine websites, newsletters, or other activities. You may find additional information about those practices in RealityMine’s website privacy policy at https://www.realitymine.com/privacy-policy.

This Privacy Policy does not apply to information that we process on behalf of our business clients while providing services to them. Our use of information that we process on behalf of our business clients is governed by our agreements with such clients. If you have concerns regarding your personal information that we process on behalf of our business client, please direct your concerns to the business with which you have a relationship.

Table of Contents

Who are we?

We are a consumer behavior insights company that uses passive technology to measure how real people use digital devices, apps and websites. Our technology provides our clients with detailed, opt-in data on cross-media consumption and advertising.

Personal information we collect

Information you provide to us. Personal information you may provide to us includes:

Automatic data collection. If you participate in a Research Program, we automatically collect data about you, including through our Application Meter, VPN or browser extensions.

The Application collects “clickstream data” and may also gather diary/survey data if you provide it. Clickstream data is information generated by your device while you use the Internet and interact with various sites, services, mobile apps, and device functions.

Once installed, the Application will walk you through any necessary steps to enable automatic data collection, such as enabling certain device permissions, setting up the “VPN” (a profile on your device to direct all internet data generated by and for your device through us to enable us to collect the data) or browser extensions. Regardless of the technical means used to collect this data, we will use the data as described in this Notice.

On Android and iOS mobile and tablet devices, we may use a VPN to collect the web traffic for applications and websites. Panelists may be asked to install a root certificate which is used to decrypt the HTTPS traffic from specific browsers and applications. This enables us to collect, the URL and some specific HTTP headers. We do not collect passwords or credit card details. This data is used to report on web pages the user visits, including those of video services when using the browser.

On Android devices, a unique security certificate is created randomly for each device. This means that only that specific device can read the encrypted data. No one else (including RealityMine, our Panel Partners, or our customers) can decrypt or view that traffic outside of the device.

On Windows and OSX devices, we may use browser extensions to collect the web traffic from websites.

We collect the following categories of data. Listed under the below categories of data are examples of the types of data that we collect; this is not a comprehensive list of every single data element.

Information collected from third-party sources. We may combine personal information we receive from you with personal information of the kinds identified above as well as additional categories of data that we obtain from other sources, such as:

Tracking technologies. Some of the automatic collection described above is facilitated by the following technologies:

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

Compliance and protection. We may use your personal information to:

With your consent. In some cases, we may specifically ask for your consent to collect, use, or share your personal information for further purposes, if those purposes are not compatible with the initial purpose for which that personal information was collected.

Cookies. In addition to the other uses included in this section, we may use the Cookies described above for the following purposes:

Analytics. To help us understand user activity on the Service, including apart from the Application and link that data to other data in your profile, including data that is collected through your use of the Application.

Data sharing in the context of corporate transactions. We may share certain personal information in the context of actual or prospective corporate transactions – for more information, see How we share your personal information, below.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so, such as between RealityMine and our Panel Partner and to our clients.

In choosing to participate in this research program, you are agreeing to us sharing your data with our client Meta Platforms, Inc and its subsidiaries and affiliates, including without limitation, Facebook and Instagram (“Meta”), in connection with your participation in this Research Program. Your data (including your personal data, Application collected data, and other data that is referenced in this policy) may be used for Meta’s lawful business purposes, including to better understand information about, and the consumer behavior of, you and to help Meta provide and improve its ads products and services. Meta may combine such collected data with other data and information that Meta has about you (e.g., Facebook and Instagram usage). For full information on how Meta uses personal data, you can find its privacy policy here: https://www.facebook.com/privacy/policy/.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, internet service providers, information technology, order fulfillment, customer support, online chat functionality providers, email delivery, marketing, consumer research and website/data analytics).

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties in litigation, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Corporate transactions. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in RealityMine or our Panel Partner, financing of RealityMine or our Panel Partner, public stock offerings, the sale, transfer or merger of all or part of our business, assets or shares, liquidation or reorganization). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may disclose your personal information to an acquirer, successor, or assignee of RealityMine or our Panel Partner or a portion of our business assets as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Your choices

In this section, we describe the choices available to you.

Opt Out:

Please note that you will be automatically opted out at the end of the program.

Participation in this Research program is voluntary. If you would like to opt out before the end of the program you may do so at any time by contacting Sago. If you have any questions regarding removal or opting-out, please contact Sago by using this email address: trendstudy@insightsmr.org

If you are a Sago research program panelist, you will need to remove the Application from your device. If you would like to opt-out, please read and follow all defined steps of the Application Removal Instructions below.

a) If you are using an Android phone, simply open ‘Settings’, scroll down to Apps, find TrendStudy, and then click ‘Uninstall’. This will also remove the VPN profile. You will then need to remove the Root Certificate from your settings if applicable.

b) If you are using an iPhone, simply hold down on the app icon. When an ‘X’ appears above TrendStudy, tap the ‘X’ to remove the application. You must then remove the VPN profile from your device by going to ‘Settings’, ‘General’, ‘Profiles’ and then removing the VPN profile and root certificate if applicable.

c) If you are using a Windows machine, find TrendStudy in ‘Programs and Features’, double click to bring up the uninstallation wizard and click ‘Uninstall’. Following these steps will automatically remove all browser extensions.

d) If you are using an OSX machine, Force Quit TrendStudy, drag the application to the trash and then empty the trash. Following these steps will automatically remove all browser extensions.

If you have set your browser to “private browsing” or a similar setting, the Application may still continue to operate and collect data to be sent to Us. To completely stop the operation of the Application and the collection of data from your device, you must follow the instructions above to remove the Application. As an alternative, you have the option to temporarily pause data collection from within the application

If you do not opt out, but do disable the collection of Digital Data, you may no longer be eligible to participate in the Program.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account and navigating to your account profile and settings.

Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit http://www.allaboutcookies.org.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Retention Period for Personal Information. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, including Sensitive Personal Information, we may consider factors such as the length of time we have an ongoing relationship with you and provide services to you; the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations; and applicable legal requirements. For example, we will retain your personal information for as long as you have an account with us or keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise. When we no longer require the personal information we have collected about you, we may either delete it or de-identify it.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organizational and physical safeguards that are designed to protect the personal information we collect. However, security risk is inherent in all Internet and information technologies, and we cannot guarantee the security of your personal information.

When your information is sent over the public Internet by the Application, it is transmitted through either a secure means of encryption, or the same means of transmission used by your device in the absence of the Application. For example, information normally sent by your device in an encrypted fashion is sent by the Application to us in an encrypted fashion. Similarly, information normally sent by your device in an unencrypted fashion may be sent by the Application in that format, or we may choose to send it in an encrypted fashion. In other words, the Application does not reduce the security procedures that your device uses to transmit information.

International Data Transfers

We are headquartered in the United Kingdom and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Where personal information is transferred outside your country, all reasonable measures will be taken to ensure it remains protected to a standard comparable to that set out in this Privacy Policy. Reasonable measures will also be taken to maintain the security of personal information during transit and at the receiving location.

Children and Teens

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a minor from whom you believe we have collected personal information in a manner prohibited by law, or if information was provided on your behalf when you were under 18, please contact Sago via trendstudy@insightsmr.org and RealityMine via dpo@realitymine.com. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. We reserve the right to modify this Privacy Policy at any time. We will notify you by updating the “Last Updated” date. Depending on the kind of change we make, we may also notify you directly or ask for your consent to the change. Any modifications to this Privacy Policy will be effective upon our posting the modified version or as otherwise indicated at the time of posting.

How to contact us

U.S. State Privacy Rights Notice At Collection

Except as otherwise provided, this section applies to residents of list states with privacy laws known to be applicable to this client – California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, and other states to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively the “State Privacy Laws”).

This State Privacy Rights Notice At Collection is part of our full Privacy Policy. As described above, this Notice applies to personal information that we collect from respondents who agree to participate in a Research Program that involves downloading and installing an Application, as well as other activities described in this Privacy Policy above. It does not apply to data collected through our websites, newsletters, or other activities.

This section describes how we collect, retain, use, disclose, sell and share for the purposes of targeted advertising personal information of residents of these states and the rights these users may have with respect to their personal information. Please note that not all rights listed below may be afforded to all individuals and that if your state does not afford you these rights, you may not be able to exercise these rights. In addition, we may not be able to process your access, correction or deletion request if you do not provide us with sufficient detail to allow us to confirm your identity and understand and respond to your request.

For purposes of this section, the term “personal information” means information that relates to an identified or identifiable natural person, or that is reasonably capable of being used to identify, contact, or precisely locate a natural person, household, or a particular computing system or device.

We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.

Your privacy rights. You may request to exercise the rights listed below. We will respond to your request in accordance with applicable law. We may decline to honor your request where an exception applies.

Right to know

Exercising your right to know, access, correction, deletion, revoke consent and appeal. You may submit requests to Sago via trendstudy@insightsmr.org and RealityMine via dpo@realitymine.com.

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Verification of Identity; Authorized agents. Please contact the Panel Partner (the panel that you are a member of) if you have any request. In the unlikely event that our Panel Partner is unable to assist you with your requests, we may need to verify your identity to process your requests so that we know who you are. This is so that we can investigate your request and take appropriate action, which may include accessing, correcting, deleting the personal data that we hold on you, or appealing the request and reserve the right to confirm your residency. We may need to request the name of the panel that you are a member of (Panel Partner name), your panelist ID number, the invite code you used to sign up to this research program, your first name, your last name, email address, in order to verify your identity and protect against fraudulent requests. If you make a request to delete, we may ask you to confirm your request before we delete your personal information.

Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. Depending on the kind of request you have made, we may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Law rights on your behalf, the information we request to verify your identity, or confirmation that you have given the authorized agent permission to submit the request.

Personal information that we collect, use and disclose. We have summarized the personal information we collect and may disclose, sell to or share with third parties by reference below to both the categories of personal information defined in the “Personal Information we collect,” “How we use your personal information,” and “How we share your personal information” sections of this Policy above and the categories of personal information specified in state law. This table describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.

See our full Privacy Policy for descriptions of each entry in this table.

Personal Information (“PI”) we collect

California statutory category of PI

Business/commercial purpose for PI collection

Categories of third parties to whom we “disclose” PI for a business purpose

Contact data

Identifiers

Customer records

Service delivery and operations

Compliance and protection

Analytics

Corporate transactions

Service providers

Third parties designated by you

Professional advisors

Authorities

Counterparties and advisors/professionals in corporate transactions

Research and demographic data

Customer records

Protected characteristics

Service delivery and operations

Research and development

Compliance and protection

Analytics

Corporate transactions

Profile data

Identifiers

Customer records

Sensitive personal information

Employment information

Internet activity

Service delivery and operations

Research and development

Compliance and protection

Analytics

Corporate transactions

Communication data

Commercial information

Internet activity

Service delivery and operations

Research and development

Compliance and protection

Analytics

Corporate transactions

Marketing Data

Commercial information

Internet activity

Inferences

Service delivery and operations

Compliance and protection

Analytics

Corporate transactions

Device data

Identifiers

Internet activity

Geolocation data

Service delivery and operations

Research and development

Compliance and protection

Analytics

Corporate transactions

Location Data

(approximate)

Geolocation data

Service delivery and operations

Research and development

Compliance and protection

Analytics

Corporate transactions

Communication interaction data

Commercial information

Internet activity

Service delivery and operations

Research and development

Compliance and protection

Analytics

Corporate transactions

Online activity data

Commercial information

Internet activity

Service delivery and operations

Research and development

Compliance and protection

Analytics

Corporate transactions

Tracking technology data

Identifiers

Internet activity

Service delivery and operations

Research and development

Compliance and protection

Analytics

Corporate transactions

Inferences from the above kinds of personal information

Inferences

Service delivery and operations

Research and development

Compliance and protection

Analytics

Corporate transactions

Consumers under 18. We do not have actual knowledge that we have collected, sold, or shared the personal information of residents who are under 18 years of age.

Additional information for Nevada residents. Nevada residents have the right to opt-out of the sale, as defined, of certain personal information for monetary consideration. While we do not currently engage in such sales, if you are a Nevada resident and would like to make a request to opt out of any potential future sales, please email dpo@realitymine.com.

Retention Period for Personal Information. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, including Sensitive Personal Information, we may consider factors such as the length of time we have an ongoing relationship with you and provide services to you; the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations; and applicable legal requirements. For example, we will retain your personal information for as long as you have an account with us or keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise. When we no longer require the personal information we have collected about you, we may either delete it or de-identify it.

Additional information for Connecticut residents. We do not collect, use, or sell personal data for the purpose of training large language models (“LLMs”).

Contact Us. If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the How to contact us section, above.