Last updated April 20, 2021

Iterative Education App Privacy Policy

At Iterative Education App (“Iterative Education” or "we" / “our”) data protection and confidentiality is a high priority.

This Privacy Policy explains how personal information about you is collected, shared and used by Iterative Education and how you can exercise your privacy rights. This Privacy Policy applies to personal information that we collect when you use our mobile game applications, forums, websites and other online products and services (collectively, the “Services”) or when you otherwise interact with us.

This Privacy Policy governs all our Services.

We may amend and/or update this Privacy Policy from time to time by posting a new version in response to changing legal, technical or business reasons and developments. If we make material changes, we will notify you by revising the date at the top of the notice and, depending on the specific amendments, we may provide you with additional notice. We encourage you to review the Privacy Policy whenever you access our Services to stay informed about our information practices and the ways you can help protect your privacy. Your continued use of the Services shall mean your acceptance of the changes to this Privacy Policy.

Information we collect

Information you provide to us

We collect information you provide voluntarily to us, such as when you participate in a contest and promotion, communicate with us via third party social media sites, request customer support, send us an email or otherwise interact with us. The types of information we may collect about you include your name, social networking screen names or IDs, email address and any other information you choose to provide.



Information we collect automatically

When you access or use our Services, we automatically collect certain information from you and/or your device (which may be considered personal information under applicable data protection laws). We collect this information with your either your explicit consent in accordance with GDPR article 6(1)(a) or as part of our legitimate interest in accordance with GDPR article 6 (1)(f)., including:

• Age: when you download our game, we collect your age as indicated by you.

• Pseudo: when you download our game, we collect your pseudo as indicated by you.

• Device information: about the device you use to access our Services, including information about the device’s type, software and hardware, Media Access Control (“MAC”) address and other unique device identifiers (such as Device ID and Advertising ID), device token, mobile network information and time zone.

• Location information: We collect location information in order to comply with legislation and policies that apply to your area. However, neither we nor our partners collect location information more granular than city level without your explicit consent.

• Usage information: relating to your use of our Services, including which applications you use and your interactions.

• Consumption information: about your consumption habits relating to your use of our Services, including which purchases you make with virtual currencies.

• Information from third party surverys: We may invite you to participate in surveys facilitated by third party survey partners. From these services we will collect the information you provide as well as your pseudo in order to be able to match it with your in-game information. You will always be made aware that you are being transfered to the third party service before the collection starts and thus have the opportunity to opt out. The partners policies will be made available to you and we encourage you to review them before participating in the survey.


Our Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature and information about your game status and progress, etc. may be showed on these media. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Our Services may contain links to websites, social media, platforms etc. We are not responsible for the contents of the websites, social media, platforms etc. of other companies or for the practices of such companies regarding the collection of personal information.

How we use your information

We may use information about you for various purposes, including to:

• Provide, maintain and improve our current Services;

• Develop new Services;

• Provide and deliver the products and services you request and send you related information;

• Respond to your comments, questions and requests and provide customer service and support;

• Send you technical notices, updates, security alerts, push notifications and support and administrative messages;

• Communicate with you about products, services, offers, promotions and events offered by Iterative Education and others, and provide news and information we think will be of interest to you;

• Personalise and improve our Services with the use of profiling to provide targeted advertisements, content or features;

• Process and deliver contest entries and rewards;

• Monitor and analyse trends, usage and activities in connection with our Services;

• Link or combine with information we get from others to help understand your needs and provide you with better service;

• with

Carry out any other purpose for which the information was collected.

However, we do not request or intend to collect any “special categories information” such as information on health, race, religion, political opinions, sexual preferences or orientation. Be cautious when sharing this information about yourselves (or others) in our Services.

How we may disclose your information

We may share information about you as follows or as otherwise described in this Privacy Policy:

• With other users of our Services;

• In response to a request for information if we believe disclosure is in accordance with any applicable legal requirement;

• If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of Iterative Education or others;

• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; and

• With your consent or at your direction.

We also may share aggregated information or otherwise anonymised information, which cannot reasonably be used to identify you.

International Data Transfers

Iterative Education operates globally and our Services are global by nature. Your personal information collected via and/or by Iterative Education may be stored anywhere in the world and may be transferred to, and processed in, countries other than the country of which you are a resident. These countries may have data protection laws that are different from the laws of your country.

When we transfer your personal information internationally, Iterative Education takes steps to ensure that adequate safeguards are in place to protect your personal information and it is treated securely, lawfully and in accordance with this Privacy Policy.

Data retention

We retain your personal information collected as described in this Privacy Policy for as long as needed to provide you the Services or we have a legitimate business reason to do so.

When we no longer have ongoing legitimate business reason to process your personal information, we will delete your data.

Security

We have implemented security measures to ensure that our internal procedures meet our high security policy standards. Accordingly, we strive to protect the quality and integrity of your personal information. This includes encryption of data and use of pseudonymisation, whenever applicable.

Your data protection rights

You are at any time entitled to be informed and/or access the personal information about you that we process, but with certain legislative exceptions. You have the right to:

i) object to the collection and further processing of your personal information;
ii) have your personal data updated, rectified, erased or blocked;
iii) receive information about you that you have provided to us;
iv) opt out of certain uses and disclosures of your personal information; and
v) have your personal information transmitted to another data controller (data portability). In order for you to exercise your data protection rights we are obliged to verify your identity.

We can only verify your identity if you are logged in on one of our Services. You will therefore only be able to exercise your rights if you log in and follow the steps as explained.

If you want us to update, amend or delete the personal information that we have collected about you, wish to get access to the data being processed about you, or if you have any questions concerning the this Privacy Policy, you may contact us by email at contact@playlearner.com.

Withdrawal of consent

You may, at any time, withdraw any consent you have given, and we will no longer process your personal information, unless we can continue the processing based on another purpose. If you wish to withdraw your consent, you can withdraw it by contacting us using the contact information below.

Age, Children

Our Services are not intended for children.

Iterative Education has implemented age-gate to its games to verify players’ age.

If you are a parent or legal guardian of a child under the age of 13 (or under 16 in certain jurisdictions in the European Union) who uses our Services, please contact us at
contact@playlearner.com, if you have any questions or comments. On your request we will delete your child’s personal information if we are able to identify your child, unless you provide us with your verifiable consent for your child to continue to use our games.

How to contact us

If you have any questions about this Privacy Policy, please contact us:

Name of the Data controller:

Iterative Education
2 allée du bord de l'eau, 75016, Paris, France
contact@playlearner.com

Complaints

If you wish to appeal against the processing of your personal information, please contact us as indicated above.