last updated on 25th May 2018
GameSalad, Inc. (“GameSalad”) respects your privacy and is committed to protecting your personal data.
GameSalad has two major focuses, one aimed at developers (“GameSalad”), and one aimed for educational use in districts and schools (“GameSalad for Education”). All of our developer focused services, such as the forums, are not intended for children, and do not knowingly collect data relating to children.
Our products and services that make up GameSalad for Education do collect student data, but fully within the bounds of COPPA compliance. Refer to the Children’s Privacy section below.
Important information and who we are
Our full details are:
Full name of legal entity: GameSalad Inc.
Title of data privacy manager: Data Protection Representative
Email address: firstname.lastname@example.org
Mailing address: PO Box 80288, Austin TX, 78708
You have the right to make a complaint at any time to the proper authorities. We would, however, appreciate the chance to deal with your concerns before you approach any authorities so please contact us in the first instance.
This version was last updated on 25th May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The data we collect about you
Data You Provide to Us
We may collect different data from or about you depending on how you use the Site. Below are some examples to help you better understand the data we collect.
When you create an account and use the Site, including through a third-party platform, we collect any data you provide directly, including:
|Account Data||In order to use certain features (like the GameSalad Creator software), you need to create a user account. When you create or update your account, we collect and store the data you provide, like your email address, password, username, and occupation, and assign you a unique identifying number (“Account Data”).|
|Profile Data||You can also choose to provide profile information like a photo, headline, website link, social media profiles, or other data. Your Profile Data will be publicly viewable by others.|
|User Content||We store all published projects, but only access them when requested to in conjuction with providing quality assurance or support.|
|Shared Content||Parts of the Site let you interact with other users or share content publicly, including by posting comments or reviews on a provided course, asking or answering questions, sending messages to other users, or posting photos or other work you upload. Such shared content may be publicly viewable by others depending on where it is posted.|
|Course Data||When you enroll in and take courses, we collect certain data including which courses, assignments and quizzes you’ve started and completed; your exchanges with instructors, teaching assistants, and other students; and essays, answers to questions, and other items submitted to satisfy course requirements.|
|Payment Data||If you make purchases, we collect certain data about your purchase (such as your name and zip code) as necessary to process your order. You must provide certain payment and billing data directly to our payment processing partners, including your name, credit card information, billing address, and zip code. For security, GameSalad stores sensitive cardholder data, such as full credit card numbers and card authentication data, with trusted secure processor partners, and has no access to such data.|
|Data About Your Accounts on Other Services|
Data we Collect through Automated Means
When you access the Site or Platform, we collect certain data by automated means, including:
|System Data||Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types (“System Data”).|
|Usage Data||Usage statistics about your interactions with the Site, including time spent on pages or the Site, pages visited, courses accessed, features used, your search queries, click data, date and time, and other data regarding your use of the Site (“Usage Data”).|
|Approximate Geographic Data||An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.|
The data listed above is collected through the use of server log files and tracking technologies, as detailed in the “Cookies and Data Collection Tools” section below. It is stored by us and associated with your account.
Special Categories of Data
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
How is your personal data collected?
Cookies and Data Collection Tools
GameSalad uses the following types of cookies:
Preferences: cookies that remember data about your browser and preferred settings that affect the appearance and behavior of the Site (like your preferred language).
Security: cookies used to enable you to log in and access the Site; protect against fraudulent logins; and help detect and prevent abuse or unauthorized use of your account.
Functional: cookies that store functional settings (like the volume level you set for video playback).
Session State: cookies that track your interactions with the Site to help us improve the Site and your browsing experience, remember your login details, and enable processing of your course purchases. These are strictly necessary for the Site to work properly, so if you disable them then certain functionalities will break or be unavailable.
Some of the third-party partners who provide certain features on our site may also use Local Storage Objects (also known as flash cookies or LSOs) to collect and store data.
We use third-party browser and mobile analytics services like Google Analytics, and Freshdesk on the Site. These services use Data Collection Tools to help us analyze your use of the Site, including information like the third-party website you arrive from, how often you visit, events within the Site, usage and performance data, and where the application was downloaded from. We use this data to improve the Site, better understand how the Site performs on different devices, and provide information that may be of interest to you.
How we use your personal data
We use your data to do things like provide our Site, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Site, analyze how people use our Site, serve personalized advertising, and as required by law or necessary for safety and integrity.
We use the data we collect through your use of the Site to:
- Provide and administer the Site, including to display customized content and facilitate communication with other users;
- Process your requests and orders for products, specific services, information, or features;
- Communicate with you about your account by:
- Responding to your questions and concerns;
- Sending you administrative messages and information, notifications about changes to our Site, and updates to our agreements;
- Sending you information and in-app messages about new services, new features, promotions, and newsletters (which you can opt out of at any time);
- Manage your account preferences;
- Facilitate the Sites’ technical functioning, including troubleshooting and resolving issues, securing the Site, and preventing fraud and abuse;
- Solicit feedback from users;
- Market and administer surveys and promotions administered or sponsored by GameSalad;
- Learn more about you by linking your data with additional data through third-party data providers or analyzing the data with the help of analytics service providers;
- Identify unique users across devices;
- Tailor advertisements across devices;
- Improve our Site and develop new products, services, and features;
- Analyze trends and traffic, track purchases, and track usage data;
- Advertise the Site on third-party websites and applications;
- As required or permitted by law; or
- As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Site.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased products or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
We do not reach out directly to educational accounts for marketing or otherwise. All technical support for student accounts is addressed through the educator or admin responsible for the accounts.
CHILDREN UNDER 13
For Personal Accounts on gamesalad.com
To ensure compliance with The Children’s Online Privacy and Protection Act (“COPPA”) regulations, GameSalad recognizes the privacy interests of children, and we encourage parents and guardians to take an active role in their children’s online activities and interests. GameSalad’s services and the Site are not intended for children under the age of 13 without the consent of a parent or legal guardian. GameSalad endeavors not to collect any personally identifiable information from children under the age of 13. GameSalad designs its services and this Site to adults and not individuals under the age of 18. Personal Account Holders may utilize the service. Users under the age of 18 may do so only with the involvement of a parent or legal guardian.
For GameSalad For Education Accounts
In a classroom scenario, educators can keep students’ privacy protected and still use GameSalad by creating accounts owned by the educator or institution and ensuring that students do not divulge any personally identifiable information. COPPA requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13. Therefore, we only collect personal information through the Services from a child under 13 where that student’s school, district, and/or teacher has agreed to obtain parental consent for that child to use the Services and disclose personal information to us or where the parent or legal guardian of a child has signed the child up to use the Services.
If you are a student under 13, please do not send any personal information about yourself to us if your school, district, and/or teacher has not obtained this prior consent from your parent or guardian or if your parent or guardian has not signed you up to use the Site, and please do not send any personal information other than what we request from you in connection with the Services. If we learn we have collected personal information from a student under 13 without parental consent being obtained by his or her parent, guardian, school, district, and/or teacher, or if we learn a student under 13 has provided us personal information beyond what we request from him or her, we will delete that information as quickly as possible. If you believe that a student under 13 may have provided us personal information in violation of this paragraph, please contact us at email@example.com.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Service providers who provide IT and system administration services.
- Service providers who provide customer service tools such as online chat services and helpdesk services.
- Third parties who provide personalized icons for use on our Site.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Third party payment processors who securely store payment data.
- Our third party analytics partners to analyse Site traffic and understand customer needs and trends.
- Third parties if we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Site or customers.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
You can request further details of retention periods for different aspects of your personal data by contacting us.
In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.