Privacy Policy

This Privacy Policy explains how MindPlay Education, LLC collects, uses, discloses, and secures personal information through our website, our MindPlay online web application, or any social media page we maintain that contains a link to this Privacy Policy (collectively, the “Service”) and through other interactions with individuals who reach out to us directly by email or telephone. As used in this Privacy Policy, “personal information” means information that identifies, relates to, or describes an identified or identifiable natural person.

The Service is only for use by children under 13 who have been provided with an account by their parent/legal guardian or teacher, or as to which we have otherwise received parental consent. Such consent may be revoked at any time by calling us at 800-221-7911 or sending an email to info@MindPlay.com. The personal information of children will be collected, used, or disclosed for the purposes of providing educational services via the Service and not for any other commercial purposes.

Table of Contents

1.  INFORMATION COLLECTION AND PROCESSING
We collect and process information including personal information for our internal and Service-related purposes.

Account registrations. When you register for an account, we collect personal identifiers (such as your name, username, mailing address, email address, and telephone number), educational institution-related information (such as your title, the educational institution name, district, and address, and the administrator’s name, title, email, and telephone number), the subscription(s) you purchased, your payment information including payment cardholder data, and any related details you submit through the Service. We use that information for account administration, security, order fulfillment, and marketing purposes.

We also collect students’ personal information that you provide when you add a student to the account, such as the students’ personal identifiers (such as their name or identification number) and education-related information (such as their grade).

Use of the Service.

By students: When students, including children under 13, use the Service, their personal information will be collected and used to provide education services via the Service. We may collect the following personal information from students: information concerning their use of and interaction with the Service, such as information on the student usage, activity, and responses. Student information including personal information may be used to improve or promote our products.

By parents/legal guardians, teachers, or those with parental consent: When you use the Service, your personal information, such as information concerning your use of and interaction with the Service, will be collected and used to provide the Service and we may also use the information to improve our Service or other aspects of our services and, where appropriate, for marketing purposes.

By teachers using professional development services: When you use the professional development services on the Service, your personal information, such as information concerning your use of and interaction with the Service, will be collected and used to provide education services via the Service and we may also use the information to improve our Service or other aspects of our services and, where appropriate, for marketing purposes.

Information Use and Ownership. All information collected and generated by the use of the Service is owned by you. MindPlay grants itself access to information including personal information for the purposes outlined above.

Contact or request submissions. When you use a contact or request form through the Service, we collect personal information from you to evaluate and respond to your request, and we may also use the information to improve our Service or other aspects of our services and, where appropriate, for marketing purposes. For example, we may collect the following personal information from you:

• personal identifiers, such as your name, email address, and telephone number;
• whether you are a school or a parent;
• educational institution-related information (such as your title, the educational institution name, district, and address, and the administrator’s name, title, email, and telephone number); and
• message content.

Communications. We receive information through your communications with us by email or phone, and we process this information to respond to you and in the normal course of our business operations and to communicate with you for marketing and informational purposes. For example, we may receive the following personal information from you:

• personal identifiers, such as your name, email address, and telephone number;
• professional or educational institution-related information, such as your job title and the educational institution name; and
• message content.

Social media. If you post information on our webpage on a social media platform, we may use the information to respond to your post, promote our business and services, and in the normal course of our business operations. We may collect personal identifiers, such as your social media username, and other personal characteristics that you have made publicly available on the social media website. Note that the third-party operators of social media websites also receive such information and your posts, and their use of your personal information is governed by their own privacy policies.

Automatic data collection: Cookies and related technologies. When you use our Service, we and our third-party partners, such as advertising partners and analytics providers including Google Analytics, collect information by automated means. Such means include the use of cookies, web beacons, and web server logs.

We may use such technologies to collect personal identifiers (such as your IP address), information about your device (such as your browser characteristics, device IDs and characteristics, operating system version, and language preferences) and information concerning your usage of our Service (including the link you used to reach a given webpage). We use this information to determine how many users have visited particular webpages, viewed particular videos or other content, or opened messages or alerts, and we may also use such information to improve the performance of the Service, to improve our marketing activities, and to enforce our website service terms, prevent malicious conduct, and for anti-fraud and security purposes.

In some cases, our third-party partners may process information collected by cookies and related technologies that we permit them to use on the Service. Please see our Cookie Policy for more details. With respect to any social media pages that we may use, please see the privacy policies and any cookie policies of the applicable social media providers as to their automated data collection practices.

As indicated above, we, like many other website operators, currently use Google Analytics to collect and process certain Service usage data. To learn more about Google Analytics and how to opt-out, please see our Cookie Policy.

You may be able to change a web browser’s settings to block and delete cookies when you access the Service through that web browser. However, if you do that, the Service may not work properly; also, we will still receive basic information (such as the last URL visited) when you navigate to the Service. Note that our website does not respond to browser do-not-track signals.

2.  INFORMATION SHARING
We may share any of the categories of personal information listed above for our business purposes as described below to assist us in providing products and services to you, including processing transactions, delivering products at your request, or helping us market to consumers.

Educational Institutions. We share information, including personal information of students, with and as directed by educational institutions, including their authorized teachers, in connection with providing the Service.

Affiliates. We share information, including personal information, with our affiliates, and any successors thereto in the normal course of our business operations, such as to communicate with you and to promote and provide our services. In this regard, personal information may be shared with one of our affiliates for use in providing a service to us.

Vendors and service providers. We share information, including personal information, with vendors and service providers that process such information to perform services for us in connection with the Service or our other business operations. For example, if you purchase a subscription, we provide your payment card information to our trusted payment card processor. We also may access, preserve, and disclose the information if we believe that such action is necessary in our judgment to comply with a legal obligation or to protect and defend our rights or property, or those of others. For example, we may provide information, including IP address information, to our service providers to protect the Service, such as for fraud detection purposes.

Legal and similar disclosures. We may share personal information with law enforcement, the courts, our advisors, attorneys, and others who participate in the legal process, if we believe doing so is required or appropriate to: comply with legal requirements and law enforcement requests (such as a court order or subpoena); comply with legal process (such as discovery); or protect your, our, or others’ rights, property, or safety.

Other sharing. We may share information as described under “Information Collection and Processing” above and for other business purposes as otherwise explained in this Privacy Policy.

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, your personal information may be shared with the other parties and advisors involved under an obligation of confidentiality in connection with the negotiation of such transaction, and your personal information may be sold or transferred as part of such a transaction to the other parties. Any such sale or transfer shall be on the condition that your personal information continues to be treated in material compliance with this Privacy Policy.

3.  DO-NOT-SELL DISCLOSURE
We do not sell your personal information for money or other consideration. We also do not rent, sell, or share “personal information” as defined by California Civil Code §1798.83 about you that we collect on the Service with other people or unaffiliated companies for their marketing purposes.

4.  INFORMATION SECURITY
We strive to process your information securely, in accordance with this Privacy Policy, and in accordance with information security requirements imposed by applicable law. We cannot, however, be responsible for Internet communications that are inherently not completely secure.

Information Encryption and Protection. All data is encrypted in transit using SSL (TLS 1.2 or higher). Personal Information is protected using encryption at rest where possible, role-based security, firewalls, and network monitoring services.

Authentication. Strong password creation is enforced for all accounts. SSO and LTI Launch sign-in options are available.

5.  INTERNATIONAL DATA TRANSFERS
You understand that we may transfer your personal information to the United States and around the world, to the extent permissible under applicable law. By providing your information and through your use of the Service, and to the extent permissible under applicable law, you agree and/or consent to such international data transfers and processing in accordance with this Privacy Policy and applicable law.

6. RETENTION OF PERSONAL INFORMATION

As a general matter, we only keep information for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law, including as necessary to comply with recordkeeping and legal obligations. Residual copies of this information may remain within our backup files, databases, and other records, and such copies are handled in keeping with our record retention procedures.

7.  PRIVACY RIGHTS
As to children under 13, the parent or legal guardian (or an authorized teacher) shall have the right to receive a description of the types of personal information collected, the right to review that information, and the right to ask that the information be deleted.

Also, certain jurisdictions impose specific legal requirements and grant privacy rights with respect to personal information, and we will comply with restrictions and any requests you submit as required by applicable law. For example, you may have the right to review, correct, and delete personal information we have about you, or to consent or withdraw consent to certain uses or sharing of personal information. If you seek to exercise your rights, please contact us by emailing info@MindPlay.com.

Please note that, when you make a request, we may require that you provide information and follow procedures so that we can verify your identity (and the applicable jurisdiction). The verification steps we take may differ depending on your jurisdiction and the request. Where possible, we will attempt to match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us do so.

We will respond to your request within the time period required by applicable law. However, we may not always be able or required to comply with your request, in whole or in part, and we will notify you in that event.

Advertising. MindPlay does not display or target users of the Service with third-party advertisements.

8.  LINKS TO THIRD-PARTY WEBSITES
The Service may contain links to third-party websites. This Privacy Policy does not apply to the practices of such other websites, and we are not responsible for the actions and privacy policies of the third parties that operate or interact with those websites.

9.  UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION
If you have questions about this Privacy Policy, or if you would like to request that we update or correct any information that you have provided to us, please send an email to info@MindPlay.com or contact us by mail at:

MindPlay Education

Attn: Brian Williams

5151 E. Broadway Blvd., Suite 1403

Tucson, AZ 85711

10.  POSTING OF A REVISED PRIVACY POLICY
We may make changes to this Privacy Policy from time to time, and the revised version will be effective when it is posted and will apply to personal information received after that date. If we make any material changes, we will provide notice of such changes on our website for a reasonable period of time (which we estimate will be approximately two weeks). We encourage you to review this Privacy Policy periodically, especially if you don’t visit our website regularly.

Effective Date: May 27, 2022.

11.  COOKIE POLICY
We use cookies and similar tools to improve the performance and security of our Service and to enhance your user experience. The following table lists cookies that may be used on our Service.

Service Provider or Trusted Partner	Purpose	Information Regarding Collection and Use of Information (Including any Personal Information)
Google Analytics* (_ga, _gid)	Services usage analytics	https://privacy.google.com/
DoubleClick and Google Ads (IDE, 1P_JAR, NID)	Online advertising	https://privacy.google.com/
Google (_GRECAPTCHA)	Website and visitor browser security	https://privacy.google.com/
Facebook (fr, _fbp)	Online advertising	https://www.facebook.com/policy.php
Windows Azure (ARRAffinitySameSite, ARRAffinity)	Delivery of service – load balancing	https://privacy.microsoft.com/en-us/privacystatement
SalesForce (BrowserId_sec, sfdc-stream, renderCtx, CookieConsentPolicy, pctrk, LSKey-c$CookieConsentPolicy)	Security and performance, and cookie consent preferences	https://www.salesforce.com/company/privacy/

*Like most websites, we use Google Analytics to collect and process certain website usage data. To learn more about Google Analytics and how to opt out, please visit https://tools.google.com/dlpage/gaoptout. In addition, you can click the following link in order to find out more information about your options with respect to Google Analytics and other Google services: https://policies.google.com/technologies/partner-sites.

You may learn more about advertising networks and opt out of receiving personalized advertisements on this browser or device from advertisers who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out options of each of those organizations. Links to those sites are here:

Network Advertising Initiative:

• Browser Opt-Out: http://www.networkadvertising.org/choices

Digital Advertising Alliance:

• Browser Opt-Out: http://www.aboutads.info/choices

Note that, when you opt-out of personalized advertising, you may continue to see online advertising on the Service and/or our ads on other websites and online services.