OVERVIEW

As a company offering a digital service online that collects personal information from people, we are obligated to post and maintain a privacy policy that outlines:

• The information we collect
• What we do with the information
• How we store the information
• How someone can get their information removed from our services
• Who we share the information with and why
• Who they can contact for more information
• Most importantly, how we handle information from minors under the age of 13

OUR COMMITMENT TO PRIVACY

WHAT INFORMATION DOES CHANGE GAMERS COLLECT AND HOW IS IT USED?

When creating an account on the Service, we ask for birthday to identify children 12 years or younger.

If a new member identifies as a child, we collect country, username, password, parent email address, and optionally province/state, and school name

• Country is used to determine access to some features of the app. Certain features of the Service are not available to our US members.
• Username and password are used to create a unique account in the service. We actively discourage children from using their real names and license software and tools from Two Hat Security (SIFT) to catch usernames that include naughty words and personal information. We do not retain the birthday of a child after sign up.
• Parent will be contacted by the Service via the parent email address provided by the child. The Service uses the “email plus” method described in COPPA to acquire consent from a parent or guardian.
• School name can be optionally provided to allow students in our I CAN Schools program to register at their school.
• Province or state information is used to narrow down the choices when selecting school name.
• We do not hold onto the birthdate of a child following the account creation process.

If a new member identifies as an adult, 13 years or older, we collect their personal email address and city of residence.

• Email address is used by the Service to help recover lost account credentials.
• City is used present local article, project, event, and media (content) to the child.

Parents are able to provide consent for their child using the Service through a Parent Tool. The Parent Tool allows the parent to change any of the child’s information, including username and password. The Parent Tool also allows the parent to optionally provide birthday and city.

Through the Service members are able to share stories and comments, also known as User Generated Content (UGC). Stories can include a photo and up to 5000 characters of text. Comments can include up to 250 characters of text. All UGC is reviewed and moderated by Change Gamers to ensure it upholds the spirit of our Service and does not include any personally identifying information (PII). Approved UGC is made available to all members of the Service and never privately between two or more members. We believe private, or group sharing promotes negative online behaviour. We also believe it is important for parents to stay informed of their child’s activity online and as such we notify the parent via email whenever their child shares UGC. We encourage you to review the rules for posting content set forth in the “User Conduct” section of our Terms of Service.

Through the course of using the Service we will automatically collect generic usage information as set forth in the “Information collected automatically” section below. We use this information to provide the Service to the member, for security and safety purposes, or as required by law or to enforce our Terms.

We will not require children to provide more personal information than is reasonably necessary in order to participate in the Service. If we discover that we have collected information from a child in a manner inconsistent with COPPA, we will take appropriate steps to either delete the information, or immediately seek the parent’s consent for that collection. We do not disclose any personal information about children to third parties, except to service providers necessary to provide the Service, as required by law, or to protect the security of the Service or other users.

Information collected from children (including information collected automatically) is never used or disclosed to third parties for advertising, including any kind of first- or third-party behaviorally targeted advertising. Children’s personal information is never sold or rented to anyone, including marketers or advertisers.

HOW LONG DOES CHANGE GAMERS KEEP CHILDREN’S INFORMATION?

A parent must activate their child’s account within 7 days of account creation. After 7 days, the account is automatically removed and any personal information associated with the account is permanently deleted.

Once activated, we only keep a child’s personal information for as long as his or her account remains active, unless we are required by law to retain it, need it to ensure the security of our community or our Service, or to enforce our Terms.

If a child’s account is inactive for twelve months or more, Change Gamers will automatically delete the account, including all personal information provided by the child or collected by Change Gamers from the child.

Parents who wish to have their child’s account deleted can use links sent to them at the time the account was created to immediately and permanently remove their child from the Service.

INFORMATION COLLECTED AUTOMATICALLY

Like most internet-based services, we (or our service providers) may automatically receive and log generic information about you when you use the Service. For example, this could include the frequency and duration of your visits to the Service, the browser you use, and the platform of the device you use.

If you use the Service on different devices, we may link the information we collect from those different devices to help us provide you with a consistent experience across your different devices. If we do combine any automatically-collected information with personal information, we will treat the combined information as personal information, and it will be protected as per this Privacy Policy.

The technologies and information we automatically collect may include:

• Cookies and other similar technologies: We (or our service providers) may use various technologies to collect and store information when you visit our Service including, clear GIFs (also known as “web beacons”), “tags”, “scripts”, and “cookies”. We use both session and persistent cookies: a session cookie disappears after you close your browser; a persistent cookie remains after you close your browser (although it can be removed) and may be used by your browser to identify you on subsequent visits to the Service. We may also use, collect and store information locally on your device using mechanisms such as browser web storage (including HTML 5). Like many services, Change Gamers uses these technologies to tailor the Service for you, and to help the Service work better for you – for example, by remembering recent search choices.
• Device information: We may collect device-specific information such as your operating system type, hardware version, screen resolution, file and software names and types, battery and signal strength, and device identifiers. This helps us measure how the Service is performing and improve Change Gamers for you on your particular device.
• Log information: Like most online services, when you use our Service, we automatically collect and store certain information in our server logs. Examples include things like:
• Details of how you used our service, such as your activity on the Service, and the frequency and duration of your visits to the Service.
• IP Address
• Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL

This information helps us make decisions about what we should work on next – for example, by showing which features are most (or least!) popular.

• Location information: When you use our Service we may collect and process information about your geographic location based on your IP address. We do this to derive amalgamated anonymized information about how well (or not!) our Services is used in certain geographic areas. We do not associate precise geolocation data with a child’s personal information and will not track the specific location of a child at a given moment in time.

HOW DOES CHANGE GAMERS USE THE AUTOMATIC INFORMATION IT COLLECTS

First and foremost, you should know that Change Gamers does not sell or rent any of your, or your child’s, personal information to any third party for any purpose — including for advertising or marketing purposes. We use the information we collect to provide the best experience. More specifically, this information is used to:

• Provide and improve the Service, for example by developing new products and features, or by reporting errors within the service.
• Respond to your requests for information or customer support.
• Customize the Service for you, and improve your experience with it.
• Most crucially, to protect our community by making sure the Service remains safe and secure.

CHANGE GAMERS DONATIONS

A key aspect of the Service is the ability for members to contribute micro donations to a project of a Non Profit Organization (NPO) or Charity and, optionally, for that donation to be match by a Corporate Sponsor (Sponsor). To make a donation, Parents must first deposit money into a child’s account via a secure online credit card payment form. The link to this payment form is provided to the parent via the email sent to the parent following account activation.

To complete the transaction, Change Gamers provides relevant anonymized, aggregated, non-personally identifiable statistics to NPOs and Sponsors. Change Gamers will never share personal information of a child with an NPO or Sponsor. Change Gamers ensures a hundred percent of the child’s donation is passed along to the NPO.

WILL CHANGE GAMERS SHARE ANY INFORMATION IT COLLECTS?

HOW DOES CHANGE GAMERS PROTECT AND SECURE MY INFORMATION?

Your I CAN App account is protected by a password. You can help us protect against unauthorized access to your account by keeping your password secret at all times.

The security of your personal information is important to us. We work hard to protect the Service, and we maintain administrative, technical and physical safeguards designed to protect against unauthorized use, disclosure of or access to personal information. In particular:

• Our engineering team is dedicated to keeping your personal information secure
• We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems
• We continually develop and implement features to keep your personal information safe – for example, when you enter any information anywhere on the Service, we encrypt the transmission of that information using secure socket layer technology (SSL) by default
• We ensure passwords are stored and transferred securely using encryption and salted hashing
• We automatically delete inactive accounts after a specific period of time, as per our retention policy, described in the “How Long Does Change Gamers Keep Children’s Information?” section

Although we make concerted good faith efforts to maintain the security of personal information, and we work hard to ensure the integrity and security of our systems, no practices are 100% immune, and we can’t guarantee the security of information. Outages, attacks, human error, system failure, unauthorized use or other factors may compromise the security of user information at any time. If we learn of a security breach, we will attempt to notify you electronically (subject to any applicable laws) so that you can take appropriate protective steps; for example, we may post a notice on our homepage (www.changegamers.com) or elsewhere on the Service, and may send email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

WHAT COMMUNICATIONS WILL I RECEIVE FROM CHANGE GAMERS?

If you registered on Change Gamers we may send you messages and updates regarding your account, including privacy and security notices, updates regarding the Service, and information regarding products, features or services from Change Gamers. If you have an account with us, we’ll also use your email address to contact you for customer service purposes, or for any legal matters that arise in the course of business.

If you download and install the iOS app on an Apple device, available from the Apple App Store, you will optionally receive push notifications for activity related to your account that occurs while you are not using the Service.

HOW WILL CHANGE GAMERS NOTIFY ME OF CHANGES TO THIS POLICY?

We may occasionally update this Privacy Policy – you can see when the last update was by looking at the “Last Updated” date at the bottom of this page. We won’t reduce your rights under this Privacy Policy without your explicit consent. If we make any significant changes, we’ll provide prominent notice by posting a notice on the Service and/or notifying you by email (using the email address you provided), so you can review and make sure you know about them.

In addition, if we ever make significant changes to the types of personal information we collect from children, or how we use it, we will notify parents in order to obtain parental consent or notice for those new practices.

We encourage you to review this Privacy Policy from time to time, to stay informed about our collection, use, and disclosure of personal information through the Service. If you don’t agree with any changes to the Privacy Policy, you may terminate your account (although we’ll be sad to see you go!). By continuing to use the Service after the revised Privacy Policy has become effective, you acknowledge that you accept and agree to the current version of the Privacy Policy.

THIRD PARTY SERVICE PROVIDERS

It’s important to us that we keep your information safe and secure. To best provide our Services, and keep your information safe, we work with a few other companies. These companies will only have access to the information they need to provide the Change Gamers service.

Here is a list of the essential service providers we work with, and their respective privacy policies to provide a great Change Gamers experience.

• Google Analytics for analytics on our website
• Kissmetrics for analytics on our app
• MailChimpa for sending email from our app
• Two Hat Security for moderating and validating usernames
• Watson from IBM for moderating and validating user generated content
• Perspective from Google for moderating and validating user generated content
• Sight Engine for moderating and validating user generated content

HOW CAN I CONTACT CHANGE GAMERS WITH QUESTIONS?