This Privacy Policy outlines how GameLab along with our affiliates and subsidiaries (“GameLab,” “we,” or “us”) treat the information we gather from users of our Services.

By visiting our website, registering for an account or utilizing our Services in any other way, you expressly consent to GameLab’s collection, storage, use and disclosure of your information as detailed in this Privacy Policy. If you disagree with any element of this Privacy Policy, you are not permitted to use our Services.

This Privacy Policy applies to all information collected from or regarding users of our websites, products, advertisements, and other services owned or operated by GameLab. This Privacy Policy outlines how and when GameLab collects, utilizes, and shares your information upon use of our services and website.

All information collected will be handled with care in accordance with GameLab’s information management guidelines and with respect for your privacy. This Policy applies to all of GameLab’s operating divisions, subsidiaries, affiliates, branches, and any additional subsidiary, affiliate, or branch of GameLab that we may subsequently form.

The types of Personal Information we may collect (either directly from you or from Third-Party sources) and our privacy practices rely on the nature of the relationship you have with GameLab and the requirements of applicable law . Some of the ways that GameLab may collect Personal Information include:

•         Should you provide Personal Information directly to GameLab through interacting with our Services, participating in surveys or during events, and requesting Services or information.
•         As you navigate the Services, certain passive information may also be collected about your visit, through cookies and similar technologies as described below.

We solely collect information relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.

GameLab collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively “Individuals”).

•         Information You Provide Directly to Us. When using the Services or engage in certain activities, such as registering for an account with GameLab, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all the following types of information[TS5] :
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•         Communications with Us. Upon request of information about our Services, the purchase of a license, email communication, a request to receive customer or technical support, we may collect Personal Information from you such as an email address, a phone number or a mailing address. You are not obliged to share your Personal Information with us, but refusal to do so would not grant you access to certain content, features and other Services.
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•           User ID and Virtual Player Numbers. Upon registry, you will be assigned a unique user identification number (“User ID”), and for each game you play, you will be assigned a game number (“Virtual Player Number”). Your User ID and Virtual Player Number are distinct from your Personal Information.
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•           Demographic Information. Upon registry, we may ask several demographic questions (e.g., what is your gender?). We refer to this type of information as “Demographic Information”. You reserve the option to decline to provide information for any or all those questions.
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•           Game Data. We collect the data of all games run using our Services, including in-game chat content (“Game Data”). Please do not reveal your Personal Information during any in-game chat, as it will be a part of the Game Data we collect.
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•           Surveys. Occasionally, we may contact you to participate in online surveys. Should you decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/or services and in any manner consistent with the policies provided herein.
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•           Automatic Data Collection. Concurrent with other online business platforms, we may automatically collect certain information through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when accessing the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that are visited before and after use of the Services, the date and time of visit, the amount of time spent on each page, information about the links clicked and pages viewed within the Services, and other actions taken through use of the Services such as preferences.
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•         Information Submitted Via Services. You consent that GameLab Education and its subsidiaries can use the content of any communication submitted through our Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for the purpose of developing, manufacturing, and/or marketing goods or Services. GameLab will not disclose your name or otherwise publicize the submission of materials or other information to us under your name unless: (a) you express your consent to do so; (b) we first send notice to you that the materials or miscellaneous information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
• ·          Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For instance, should you access our Services through a Third-Party application, such as an SNS, we may collect your information from that Third-Party application that you have made public through your privacy settings. Information we collect through SNS accounts may include your full name, your SNS user identification number, your SNS username, location, sex, birth date, email, profile picture, and your contacts on the SNS. This supplemental information allows us to verify information that you have provided to GameLab and to enhance our ability to provide you with information about our business, products, and Services.

We, as well as Third-Parties that provide content, advertising, or other functionality on our Services, may utilize cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use the Technologies, as mentioned below, within your computer, tablet, or other devices (referred to collectively as a “device“) that allow us to record information of your visit or interaction with our Sites, Services, messaging, and tools, and to recognize you across devices.

•         Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, the Site may not function properly when performed.
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•         Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. For instance, The use of a pixel allows us to record that a user has visited a certain webpage or clicked on a particular advertisement.

•         Social Media Widgets: Our Website includes links to social media platforms such as Facebook and LinkedIn (this is seen through widgets such as the “share” or “like” button, among other interactive mini-programs). These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third-Party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.

•         Analytics. We may also use analytics tools such as Google Analytics and Google Analytics Demographics and Interest Reporting [JR6] [JR7] to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to https://tools.google.com/dlpage/gaoptout.

If you wish to opt-out of the Technologies we utilize for our Sites, Services, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

The Site may contain links to other websites, whilst other websites may reference or link our Site or other Services on their platforms. We exhaust no control over these external domains and websites, and GameLab does not endorse or represent these Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not held liable for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We have no control over such uses of your information when interacting with a social media platform, and by using such services, you assume the risk that the Personal Information you provide may be viewed and utilized by third parties for any number of purposes.

We use this information to provide better service. We acquire, hold, use, and process information for a variety of purposes, including:

•         To Provide Products, Services, or Information Requested. GameLab may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including:
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•           Generally, managing Individual information, licenses and accounts;
•           Responding to queries, comments, and other concerns;
•           Providing access to certain areas, functionalities, and features of GameLab’s Services;
•           Contacting you to respond to requests for customer support or technical support;
•           Allowing you to register for events.
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•         Administrative Purposes. GameLab may use the Personal Information provided for administrative purposes, including:
•           Measuring interest in GameLab’s Services;
•           Developing new products and Services;
•           Ensuring internal quality control;
•           Verifying Individual identity;
•           Communication about Individual accounts and activities on GameLab’s Services and systems, and, in GameLab’s discretion, changes to any GameLab policy;
•           Sending email to the email address provided for account verification along with informational and operational purposes, including account management, customer service, or system maintenance;
•           Processing payment for products or services purchased;
•           Preventing potentially prohibited or illegal activities;

•         Marketing GameLab Products and Services. GameLab may use Personal Information to provide materials about offers, products, and Services that may be of interest, including new content or Services by email, as permitted by applicable law. Such uses include:
•           Tailoring content, advertisements, and offers;
•           Notification about offers, products, and services that may be of interest to you;
•           Providing Services to you and Third-Parties;
•           For other purposes disclosed at the time that Individuals provide Personal Information; or otherwise with your consent.

You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 7.

•         Research and Development. We may use your Game Data and Demographic Information for research of our own, and to enable Instructors and other Third Parties to conduct research. We will never use your Personal Information for research purposes. In fact, Game Data and Demographic Information will not be stored in the same database as your Personal Information.

GameLab may use Personal Information to create non-identifiable information that we may use separately or in the aggregate with information obtained from other sources, to help optimally deliver existing products and Services or develop new products and Services. From time to time, GameLab may perform research (online and offline) by way of survey. We may utilize Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.

•         Direct Email. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third-Parties, may receive periodic emails from us with information on GameLab’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions outlined in Section 7.
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•         Anonymous and Aggregated Information Use. GameLab may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access GameLab’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and GameLab may use such information in several ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within GameLab and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
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•         Other Uses. GameLab may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed at the time you provide Personal Information or express consent. 

Our uses of Technologies fall into the following general categories:

•         Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are essential to the operation of our Sites, Services, and tools. This includes technologies that grant access to our Sites, Services, and tools; that are required to detect irregular Site behavior, prevent fraudulent activity and improve security; or allow use of functions such as carts, saved search, or similar functions;

•         Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our Sites, Services, and tools, including as part of our analytic practices to help us understand how our visitors use our Sites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our Site content, Services, or tools;

•         Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer enhanced functionality upon use of our Sites, Services, or tools. This may include identifying log-in to our Sites or keeping track of specific preferences, interests, or previously viewed items so we may enhance the presentation of content on our Sites;

·          Advertising or Targeting Related. We may use first-party or Third-Party cookies and web beacons to deliver content, including ads relevant to your interests, on our Sites or on Third-Party Sites. This includes using technologies to understand the usefulness of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

We may share your information as described in this Privacy Policy (e.g., with our Third-Party service providers; to comply with legal obligations; to protect and defend our rights and property) with your expressed consent.

•         Instructors. The Instructor running the game will be granted access to the following information about Participants in that game: name, User ID, Virtual Player Number and Game Data. Instructors will only have access to any Demographic Information in an aggregated, anonymous form (see “All Instructors” below).

•         School: If you access our content through an academic curriculum in your educational institution, we may share personally-identifiable information about your progress, scores, results, logon and logoff times, and similar data with your institution. We do not share this information with any external entities other than your institution.

•       Vendors and Service Providers. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. GameLab has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.[JR8] 

•         Business Partners. GameLab may share Personal Information with our business partners, and affiliates for ours and our affiliates’ internal business purposes or to provide a product or service that was requested. GameLab may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with GameLab. GameLab requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which GameLab provided.

•         Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, GameLab may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected information, such as Demographic Information and past purchase history, we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements upon visit to non-GameLab related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmission of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 7.
•         Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, Demographic Information. Game Data, User ID and other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce GameLab policies or contracts; (v) to collect amounts owed to GameLab; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order to identify users in connection with their investigation of the unauthorized activities.

·          Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such an event, GameLab will direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.

All Personal Information, Demographic Information, Game Data, User ID’s and other account information collected via or by GameLab may be stored anywhere in the world, including but not limited to, in the Chile, United States, Australia, Brazil, Germany, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. In addition, this information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to GameLab, you consent to the storage of your Personal Information in these locations.

You have the right to opt-out of certain uses and disclosures of your Personal Information. Where you have consented to GameLab’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt-out of further Processing by contacting legal@gamelabeducation.com. [TS10] Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites[MP11] and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding GameLab and our Services and you will not be able to opt-out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services.

As aforementioned, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or https://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.

Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes.

You may inquire as to whether GameLab is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may send an email to legal@gamelabeducation.com or use any of the methods outlined in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of your Personal Information by GameLab. Please include your full name, email address associated with your account, and a detailed description of your data request. Such requests will be processed in line with local laws.

Although GameLab makes efforts in good faith to provide Individuals with access to their Personal Information, there may be circumstances in which GameLab is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If GameLab determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, GameLab will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

We keep your personal data as long as needed for the purpose of which it is being processed. For instance, we will retain your information for as long as your account is active or as needed to provide you services; subsequently, we will keep personal information for a reasonable period of time, which enables us to handle or respond to any complaints, queries or concerns relating to your account.

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or directly sending an email to you. You exercise the legal right to receive this notice in writing.

This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then you must immediately cease use of the Services.

•         Revision to the Privacy Policy. We may revise this Privacy Policy at our discretion, so review it periodically. If you continue to visit this Site and use the Services made available after such changes have been made, you hereby provide consent to the changes.
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•         Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, GameLab will notify you by email or as otherwise required by applicable law. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy regularly.

·          New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, GameLab will comply with the law or contract.

If you are a resident of the State of California, you may request information about our disclosure of personal information to third parties or affiliated companies for their direct marketing purposes. To make such a request, please contact us as set forth in the “Contact Us” section. You must put the statement “Your California Privacy Rights” in the subject field. We shall not be held accountable for notices not labeled, sent properly, or do not have complete information.

Non-affiliated third parties are independent from GameLab and if you wish to receive information about your disclosure choices or stop communications from such third parties, you will need to directly contact those non-affiliated third parties.

This Policy shall be implemented by GameLab and all its operating divisions, subsidiaries and affiliates. GameLab has put in place mechanisms to verify ongoing compliance with this Policy. Any Employee that violates these privacy principles will be subject to disciplinary procedures.

If you have any questions about our privacy practices, please email us at contact@gamelabeducation.com. In addition, if you wish to exclude your Personal Information from our direct marketing, or if you would like to review, update or delete your email address, mailing address or other Personal Information, or otherwise manage communications you receive from GameLab, please use the My Account link on our Site or contact us at the address above.