FOURMULA

Service are accessible from various mobile application platforms and may be downloaded from various devices (such as cell phones and tablets). When downloading one of our mobile to install it on your Child’s device, a collection of basic technical information is initiated.

We need information pertaining to the device your Child is downloading the app on. We will collect the device's technical specifics (such as build model, firmware, mainframe, carrier).

Among these technical specifics, we will detect information about the country your Child is playing from. Please refer to Section 2.2 - Launching the Service for more details.

Once your Child has downloaded the app from a store, he or she may launch it. This triggers an initialization process (which is mainly a technical operation). The purpose of this operation is to “get the app started” for your Child.

At this stage, we collect:

- Device-related technical data (device specifics and set language)

- Device identifiers (such as IDFV)

- Country (fetched from the device)

For more information regarding geolocation data, please jump to Section 2.2.4 - Focus on: Geolocation Permissions and Information.

The collection of technical data is to support the technical initialization operation.

The collection of the IP address / coarse geolocation allows us to deliver a version of the app that will be suitable to your Child’s general geographic location. It enables us to ensure that, from the moment your Child launches the service, they benefit from a service version that is suitable to local regulations.

Collection of the IDFV (device identifier) is a standard operation to link the device and to be able to further follow and support the player's activities and progression.

Please note that, in order to fulfill this purpose, we do not need to collect your Child’s IDFA/AAID. Indeed, these specific identifiers are generally used for targeted advertising purposes and to track users across apps and websites. We do not carry out such actions when the user is a Child.

Once the app has been successfully installed, your Child may launch the service. As a first step, in the cases where the service is dedicated to a family audience (including adults and children), we display an Age Gate. The Age Gate is a pop-up form, within which users must indicate their age. This form is displayed to all users and cannot be skipped.

Its purpose is to enable Fourmula to detect whether the player behind the screen is an adult or a Child, and to adapt the service's content and features accordingly (as further described below).

As previously explained in the Data Processing Overview section, the definition of a “Child” differs depending on the geographical zone (general location of the user) and on the local applicable laws and regulations.

When the user submits their age, a collection of data begins. The collection is different depending on whether the user is an adult or a child. If the user’s age is detected as a Child's, the age value will be anonymized right away and Fourmula will only retrieve and store an age status (information that the user behind the screen is a Child) but the exact age is not retrieved or stored.

If the user is detected as being a Child, we present a screen with legal and privacy documentation (Terms & Conditions, End-User License Agreement, Privacy Policy) for you (parents and/or legal guardians) to acknowledge and accept (if you decide to let your Child access the service). In case of acceptance, we will collect your consent.

Please note that the gender (which may be declared optionally) is not collected. Indeed, we consider that we do not need to know a Child’s gender for the purposes of offering the services and all the features described in this Policy.

The purpose is to gather the relevant information about the user in order to provide for a suitable version of the service and to organize the correct data collection in accordance with the user’s age status. Indeed, as we will explain in this Policy, if a user is a Child, we only allow the collection and processing of a very limited range of data for the purpose of providing the services. We also use the age status (overage/underage) to apply restrictions on certain features that we consider are too sensitive for Children to use (for instance, social features).

We operate the age screening based on our legitimate interest, as part of providing access to our services in compliance with applicable privacy regulations. We process the Information collected via the age gate based on your consent (which includes the acknowledgment and acceptance of this Privacy Policy).

Permissions govern what an app is allowed to do and access. Depending on the service’s specifics, the app may require a user’s permission to provide a feature. For instance, to allow push notifications or cross-app tracking. Most of these permissions enable the collection and/or the sharing of a user’s Information. When a Child is playing, such features are not available, as further explained in this Policy. Therefore, we do not enable Children to receive permission requests or to manage permissions pertaining to such restricted features.

The restriction of the features and corresponding permissions are handled on the level. However, users may also be able to manage the permissions relating to an app from the settings of their device. Please note that this does not affect the behavior of the service: If the user is a Child, the features and permissions will remain unavailable in any case.

None

The purpose of this section is to provide additional details and clarification about the use of your Child’s location data, as we are aware that this could be a sensitive topic.

We collect your Child’s coarse location. Coarse geolocation means that we will know that your Child will be playing from a country or geographical zone (like the United Kingdom or Brazil), but we will not collect city or street information. Please note that if your Child is playing from the USA, we will detect the state, as some specific regulations apply per state in the USA (such as the California Consumer Privacy Act (CCPA) in California). This coarse location information is detected from your Child’s device settings.

Please note that we do not collect the specific location (such as GPS geolocation data).

The purpose of the general location collection is to apply the relevant legal requirements and restrictions. For instance, to determine whether the user is a Child, we must know the user’s country to apply the correct regulation (a user who is 16 in Europe is a Child, but not in the USA).

In addition and as further explained below, we use the general location to display contextual advertising in the relevant language and in an accurate manner. As we will elaborate further below, we do not use the general location to display personalized and targeted advertising to Children.

We collect this Information based on our legitimate interest, as this collection is needed (i) to comply with the legal obligation to apply the relevant local regulation to users, (ii) to provide for the relevant and suitable services and (iii) for standard monetization purposes for the service to be provided for free (with regards to contextual advertising).

In the digital environment, “cookies” are small files that are placed on your device (for instance, on your mobile phone or computer) by the web browser you are using when you access and browse a website. These cookies allow the publisher of a website to collect or access information about you and your use of the website (or, in some cases, your browsing activities). These cookies remain on your device for a specific duration, and so does the information they gather about your activities. These practices are commonly referred to as “tracking,” as the purpose of operators is to understand your online activities and preferences.

Tracking can be a sensitive topic for parents and guardians when it comes to their Children’s online activities. We made this section to reassure you: Our mobile do not come with cookies or similar trackers!

In this Policy, we may refer to “identifiers” and to “in tracking,” but these activities are not related to cookies in any way. In fact, when your Child downloads and plays , we will collect some technical identifiers that are used to recognize your Child’s device and to collect your Child's gaming activities, progress, achievements or in-app purchases. We keep track of this information in our systems in order to be able to provide the services, for your Child to be able to retrieve the service just as he or she left it upon returning to the app, and to provide support in case of bugs or technical issues (among other purposes listed in this Policy). This does not have the same meaning, purposes and functions as cookie-related tracking on the web.

If you are keen to find out more about the use of cookies on our websites, please refer to our Cookies Policy.

When your Child is playing the service, we collect technical information in order to ensure that the service is running properly, and to keep track of your Child’s progress, achievements and in assets (including In-App Purchases where applicable). This allows your Child to retrieve their service as they left it each time they reenter the application.

We collect technical data relating to your Child’s activities in the service, such as missions completed, items collected, duration of sessions, participation in events, etc.

The purpose of this tracking collection is to provide the services and to ensure the service is secured and runs properly (which may involve debugging, anti-cheating measures and/or fraud prevention operations). The collection of aggregated data may be part of these tracking operations, for the purpose of improving the services and performance.

We process this Information based on our legitimate interest, as part of providing our related services.

Some of our services include social network-related features. The purpose is to link some in social features to social media (for instance, enabling users to invite Facebook friends, share results on Twitter, etc.). These features are only available for overage users—if the user is detected as a Child, we do not provide such options in-service.

The purpose of such restriction is to limit Children’s possible online interactions (with adults or other users in general), and to ensure that Children are not able to provide personal information to anyone.

In addition, some of our services may be accessed using a social media account (for instance, Apple, Facebook, etc.). These features facilitate the user’s access to the service. For the same reasons, these features are only available for overage users—if the user is detected as a Child, we do not provide such options.

Not applicable

Our services may include several social features, such as open chats for users to connect and have discussions, leaderboards, or options to befriend other users.

Overage users have the ability to access all of these options. However, if the user is detected as a Child, we apply restrictions to these features. For instance, Children will not be able to appear on leaderboards under their real names (we will generate a neutral name). Also, chat and friends options will be limited or unavailable in some instances (open chats will be replaced by safe chats, which allow Children to send pre-determined messages to other users, but that will prevent them from writing anything else or to disclose any information or content).

The purpose for such restrictions is to prevent Children from sharing their Information directly or indirectly (providing their real name or their address in a message or via a leaderboard username, for instance). These limitations enable Fourmula to ensure that Children are not identifiable in, and cannot be identified or contacted by other users, whether adults or kids. This is a safety standard that we implement in all of our titles to protect Children from possible harassment or harm of any kind.

This Privacy Policy is applicable to the processing of Children’s Information in, but parents should be aware that Fourmula also manages social channels and communities outside of the services as well. For instance, we offer Discord channels for specific services' users to gather and engage in discussions. Access to such communities is restricted according to the rules of the platforms. For instance, to create a Discord account and join the channels, users have to be overage per Discord’s rules.

Not applicable

We organize and offer limited-time events in our services (such as challenges, races, etc.). Some events may be handled by Fourmula, and some others may be supported by sponsors and partners. Users may be eligible to win in rewards.

If the user is a Child, we apply the relevant restrictions to allow Children to access the event, while limiting any features that could lead to collection and disclosure of their Information. This translates into restrictions on the leaderboards (Children will not be able to provide their real name), restrictions on social features (they will not be able to share their result on social media) or restrictions on open chats.

Please note that we also organize events (such as contests), which are advertised outside of the services (on Fourmula’s social media or website). When they participate in such events, users may win in-service rewards or physical rewards. This means that sometimes, a player can win in-service currencies and items, and sometimes, they can win a physical gift (T-shirts, consoles, real-life car race experience, etc.). In case physical rewards are granted, we will restrict access to the event, in order to prevent children from sharing their name, physical address and contact information with us and/or our partners.

This step does not involve the collection of additional data. As part of the in-service progress & achievements tracking, we may collect information about your Child’s performances, results or ranking in an event or a contest.

We collect this Information to operate the limited-time events and to distribute the results and rewards (carry out in-service prize delivery, if applicable).

It is possible to purchase service-related assets within our services. We refer to these as “In-App Purchases” (or “IAPs”). These are useful to obtain an item (like a specific tool or ability) or to acquire virtual currency (to spend in-service). Please note that virtual currency can be gained by playing the service, watching contextual advertising or purchasing it with real money.

These IAPs are carried out using real money, using a credit card or other form of payment associated with your account. For instance, when you play from an Apple (iOS) device, purchases are possible, as they may be linked to your iTunes account for a limited amount of time to allow easier transactions (with your prior authorization in your device settings).

To inform Parents and/or Guardians and Children that the service contains IAPs, we display a disclaimer like this one:

Additional information is also available in-service, in the "Help" and/or "Parental Info" section(s).

Please note that the message may differ depending on the country your Child is playing from and applicable local regulations.

In our services, Children are allowed to make In-App Purchases by using the virtual currency they gained by playing the service, or that was bought with real money.

We consider that Children must have your permission and support to carry out any in-app purchases upon payment in-service. In addition, you may manage your Child’s ability to make In-App Purchases. To do so, you may restrict the purchase options from your device’s settings (following the instructions included on each device). Please make sure to keep your device password safe to avoid any unauthorized access to the settings. For withdrawal or reimbursement, please refer to the policies enforced by the online store from which your Child downloaded the service.

We do not collect personal information directly from you regarding your credit card, as the purchase and billing operations are entirely managed by the Store’s billing solutions. This means that we do not receive any personal (including financial) information within this process, but the Store informs us as soon as the purchase is completed, for us to deliver the asset in-service.

In addition, we only keep track of the technical information relating to the in-service purchase itself (such as Purchase ID, date of purchase, assets bought, and currency type). This allows us to assist in case of an issue within the asset delivery process (for instance, if a bug occurs and the item is not delivered as it should be).

If an issue occurs or if you have questions regarding IAPs, please contact our customer support (directly from the service settings) and we will investigate your request. More information regarding refunds may also be found in our Terms of Use.

The legal ground to process this data is your consent, which we collect throughout the billing process.

Most of our service are free to play. It means that users do not have to pay to install the application and have access to the service. In order to be able to provide users with free-to-play, we rely on in advertising.

In our services, we may display targeted advertising to overage users (based on their consent). However, we do not display targeted advertising to Children. It means that we do not serve advertising that is tailored based on Children’s characteristics, interests and behaviors.

Children may see in-service advertising coming in different shapes (such as banners or interstitial ads), but these will be Contextual Ads only. Contextual advertising refers to the practice of displaying advertising based on the content of the service. This means that the advertising is not tailored to the Child’s precise location, age or interests, but is based on a “snapshot” of what the Child sees in the service he or she is currently playing. For instance, we could display an ad for car toys in a racing service.

In addition, Fourmula takes steps to ensure that ads are identifiable as such by Children, and to make sure the ads' content is suitable to an underage audience.

We use the Information that we previously collected to select the contextual advertising that your Child will see (technical information, information pertaining to the device, the language and the general geographical location of your Child). The information is handled on our end or detected by the technologies provided by our selected partners to select and display these ads.

Please note that when the user is a Child, we do not collect, use or share with our partners any information relating to the Child’s age, gender, precise location (as we do not collect this information in the first place), or specific advertising IDs that are used to track users across apps and websites and to display targeted advertising.

We collect your Child’s Information to display in-service contextual advertising that is suitable for Children, compliant with local applicable regulations, and to ensure that the advertising is properly delivered and displayed (in the correct language and format).

We operate this collection based on our legitimate interest (which pertains to services' standard monetization, necessary to provide a free-to-play service).

Whenever our users have questions or claims regarding the services and their rights (including their Privacy Rights, as detailed below), they may reach out to our customer support. As Parents and/or Guardians, we invite you to communicate with our customer support directly when your requests pertain to your Child, your Child’s and/or rights.

- If your Child is an active user of the service, we encourage you to contact customer support directly from the service. This way, our customer support will be able to acknowledge your Child’s service-related identifier easily and to process the request more efficiently.

- If your Child is not an active player of the service anymore, or if you simply prefer to do so, you may also reach out to customer support via our website. In such case, customer support may ask you to provide additional information to be able to correctly identify you, your Child’s account and to communicate with you. Please note that these are reasonable steps taken to help verify a parent’s identity before granting access to any personal information, to protect children’s privacy and security.

Regardless of the process you chose, our customer support team will handle your request and provide an answer within a one (1) month period from the request. However, more complex requests may take up to two (2) months to be resolved. If this is the case, you will be informed. Please note that in some cases, we may not be able to resolve the request. This may occur when we are not able to correctly identify you and/or your Child’s account. In such a case, you will be properly informed.

As part of receiving and handling your requests, our customer support has access to your identification and contact Information (such as your name and email address), and to Information regarding your Child’s service (service, country and platform). Customer support also receives technical information to identify your Child’s player profile and the relevant identifiers pertaining to their device. To monitor the request and to treat it efficiently, customer support also generates additional Information for their internal use (for instance, an identifier attached to the request, the type of request, the date of reception, etc.).

In some cases, to identify the requester (especially for persons representing someone, like parents interacting with customer support for their Child), we may need to verify the identity of the requester with a copy of an ID or a passport.

We collect such Information to provide you and your Child with support, communicate with you and respond to any requests or questions you have submitted through our customer support. This includes processing the specific requests you may have regarding your Child’s Privacy Rights (as described in Section 4 of this Policy).

The legal ground to process this data is your consent.

This Information will be kept by Fourmula as long as your request is ongoing, and for the durations indicated in 1.2.7 above. The ID/passport copies are securely deleted within 2 months of the case being closed.

Please note that this Section describes activities that Fourmula may carry out outside of the services.

Children may take part in testing services ("playtests"). In such cases, we do not reach out to or communicate with Children directly (no messages or advertising in-service). Instead, we work with our trusted playtest partners to reach out to Parents and/or Guardians, and determine the procedures of the playtests. Such playtests may occur within Fourmula’s premises (with the Parents' or Guardians’ physical presence) or remotely (online playtests, carried out with the Parents’ or Guardian’s authorization).

When a Child participates in playtests, we may collect information about their identity, country or language, and we may record their image and/or audio (voice) as part of the playtest recording. We also collect identification and contact information of Parents/Guardians.

We collect this Information to organize and carry out the playtests with the participants, and to be able to use the playtest results afterwards (to develop or improve services).

The legal ground to process this data is your consent.

In order to operate the Services, your Child’s Information may be transferred to other Fourmula studios or entities, subsidiaries, processors or third parties located worldwide (as detailed in Section 3.2 of this Policy).

We use third-party services that have limited access to your Child’s Information for specific purposes; for instance, to provide the services (analytics, optimization), to display contextual (non-targeted) or to support in-app purchases (billing providers). They assist us with our operations.

We ensure that all these partners have access to and handle your Child’s Information lawfully and securely. As such, our partnerships are supported by written agreements that contain several provisions to protect your Child’s personal information's security and confidentiality and to ensure that the partners do not misuse such information.

We are aware that advertising may be an important concern to parents and/or legal guardians. Hence, for further information, we invite you to consult an indicative list of the main advertising partners enabled to display contextual advertising within your Child’s service by clicking .

We may also disclose your Child’s Personal Data in accordance with the laws, legal procedures, litigation or compulsory requirements from the competent authorities.

We do process your Child’s Information internationally.

Fourmula is headquartered in France, and we have operations, entities and services provided in Europe, Canada, the United States and throughout the world. For instance, as previously explained, our data centers and cloud instances are located in Canada, the USA and in Europe for storage purposes. We also work with partners located and operating worldwide, including the partners displaying contextual (non-targeted) advertising in the services, and our billing partners for in purchases.

As part of our international operations, we may also transfer Personal Data to our affiliates (which means subsidiaries, parent companies, joint ventures, and other corporate entities under common ownership of Fourmula SE) from time to time for our legitimate business purposes.

This means that your Child’s Information may be accessed from foreign jurisdictions and/or shared with entities and partners outside your (and your Child’s) country.

We have taken measures to ensure that your Child’s Information is collected, used, stored and disseminated securely and lawfully, and that it will receive an adequate level of protection in the jurisdictions in which it is processed.

In order to do so, we take good care in assessing new and existing applicable privacy laws from various countries. In addition and according to the law, any overseas transfer of your Child's Personal Data is supported by a written agreement. This agreement contains several provisions to protect your personal-information security and confidentiality upon transfer and when at rest. For example, we will take certain security measures, such as the minimization of personal information (i.e., we will strictly control and limit the amount of personal information used).

When we transfer Information to other countries that do not offer privacy frameworks that are adequate to the European (GDPR) framework, our transfer agreements incorporate the most recent version of the European Commission’s Standard Contractual Clauses. These provisions allow us to ensure the application of high-level confidentiality and security safeguards when the data travels and is processed in the destination country.

We have maintained reasonable administrative, organizational, technical and physical security measures to ensure and to help protect the privacy, security, and confidentiality (“Measures”) of Fourmula information that comply with information security best practices, applicable standards, and applicable law, including:

(a) Physical access controls designed to secure relevant facilities, infrastructure, data centers, hard copy files, servers, backup systems, and equipment (including mobile devices) used to access Fourmula data, including controls to prevent, detect, and respond to attacks, intrusions, or other system failures;

(b) User authentication and access controls within operating systems, applications, equipment, and media;

(c) Security policies and practices restricting access to Fourmula data, including written confidentiality agreements and background checks consistent with Applicable Laws on all personnel who access Fourmula data or who maintain, implement, or administer the Provider's Measures;

(d) Continuous monitoring of networks, systems, and devices (including services) to ensure the privacy, confidentiality, security, integrity, and availability of Fourmula data; and

(e) Correct or resolve the vulnerability contained in the Provider's Measures within a reasonable period of time appropriate to the risk presented.

Only authorized personnel have access to Personal Data you provide to us and each employee with access to Personal Data is obligated to maintain its integrity and confidentiality.

We take, and force applicable third parties to take, reasonable precautions to protect your Personal Data against loss, misuse, unauthorized disclosure, alteration, and destruction.

Unfortunately, please remember that no data transmission can be guaranteed to be 100% secure. As a result, while we strive to protect your information, we cannot guarantee the security of your information and do not assume any responsibility for the unauthorized use of, or access to, your information that is under our control.  If you have reason to believe that your interaction with us is no longer secure, you should immediately notify us at [email protected]

In the event of a Security Incident or if there is a breach of security involving your personal information from our Services, we will inform you immediately according to your local regulations relating to the notification of information Breaches, and take commercially reasonable steps to rectify such a breach.

If you believe your personal information is being improperly used by us or any third party, please immediately notify us via email at [email protected].

India

As a parent and/or legal guardian, you are entitled to exercise privacy-related requests based on the rights granted to data subjects pursuant to applicable data protection regulations in your and your Child’s country. To facilitate such requests, we provide you with dedicated forms available at any time here.

Here is a detailed list of the rights you may exercise:

-Right to be informed about the processing of your Child’s Personal Data. As a controller of your child’s Personal Data, Fourmula must provide you and your Child with a concise, transparent, intelligible and easily accessible form, using clear and plain language regarding the Personal Data processing carried out as part of the Services. As such, we provide you with this Privacy Policy, which includes specific information for parents and/or legal guardians about the processing of children’s Information. This policy also displays dedicated sections in kid-friendly language. Additional information and clarification may of course be provided upon request, per the “How to contact us” section below.

-Right to Access your Child’s Personal Data. You have the right to request confirmation as to whether or not Personal Data concerning your Child is being processed. If that is the case, you may request access to the said Personal Data and to additional information about the purposes and methods of processing and retention.

-Right to Rectify your Child’s Personal Data. It is in your and Fourmula’s best interest to keep your Child’s data updated. As such, you may ask for the rectification of inaccurate Personal Data concerning your Child. We encourage you to keep this Information accurate at all times. You represent and warrant that the Information you provide us this way is true and correct and does not relate to anyone else other than you and/or your Child.

-Right to request the Erasure of your Child’s Personal Data. If you consider that your Child’s Personal Data has been processed unlawfully or is not needed by Fourmula, you may request the erasure of your Child’s Personal Data from our systems (also called “right to be forgotten”).

-Right to request the Restriction of your Child’s Personal Data Processing. For the same reasons, you may ask for the restriction of all or part of your Child’s Personal Data.

-Right to Data Portability. Please note that this right is not available as the Personal Data held by Fourmula is not portable from one Fourmula service to another Fourmula service, nor to other services, applications, sites and/or systems operated by other entities.

-Right to Object to the processing of your Child’s Personal Data. On grounds related to your and/or your Child’s situation, you may object to the processing of your Child’s Personal Data.

The Californian Consumer Privacy Act of 2018 (CCPA) is a privacy regulation applicable to Californian residents, which has been enforced with a view to strengthening Californian users with strong privacy rights.

- As such, California permits residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has collected, shared with, and/or sold to third parties for a business or commercial purpose during the immediately preceding calendar year.

- A Californian consumer also has the right, at any time, to opt out of any type of selling of their personal information by a business.

In fact, Fourmula does not sell any Californian users’ personal information when the user is under 16 years old.

Our team will look into your request and answer you within one (1) month, unless your request requires further investigation. You’ll be specifically informed if that is the case.

To preserve the confidentiality of your information, we must be able to correctly identify you. For this reason, we may ask you to provide us with additional information via the request form, including your name, email address and phone number (to be able to contact you as part of the process of handling your request). In addition, as part of our communication with you, we may require a copy of an official document to prove your identity. This copy will be safely destroyed within two (2) months of your request being received and closed.

You will be informed that the above requests may affect your Child’s service's functionality, Services and features. Indeed, some of your Child's Information and its processing is mandatory for Fourmula to provide the Services. As a consequence, your actions may force Fourmula to cease providing all or part of the Services. Precisely, when the conditions below apply, your Child’s service will be reset (this means that progress, achievements, and purchased items, if any, will be lost and will not be retrievable in any way afterwards):

-when you ask for the modification of this mandatory information, we may not be able to continue to link the service or Services to you;

-when you request limitations to processing that are mandatory for Fourmula, or you object to such processing (in which case, we may not be able to provide you with the Services);

-when you withdraw your consent or ask for the deletion of your Information.

If you withdraw your consent or ask for the deletion of your Child's Information, we will not use or process your Information anymore, but we will archive it to answer regulatory or police requests. We also reserve the right to retain an archive of such information for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such information.

Disclaimer - In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another person. Additionally, we will not honor your request when an exception applies, such as when the disclosure of Personal Data would adversely affect the rights and freedoms of another person.

This Privacy Policy is governed by the laws of India.

Any dispute arising from the use of the Services shall be submitted to the competent courts of Mumbai,India.

We reserve the right to change this Privacy Policy at any time. In the event that we make material changes to this Privacy Policy, they will be re-posted in the "Privacy" section of our websites and apps with the date the modifications were made indicated at the top of the page. Therefore, we encourage you to review this Privacy Policy from time to time so that you are aware when any changes are made to it.

In addition, when changes to this Policy are made, users will be notified through a pop-up or welcome screen at the launch or re-launch of the service, prompting Parents and/or Guardians to review and acknowledge the updated Policy. If you do not accept any changes, you may choose not to use the Services or not to enable your Child to use the Services, and opt out by sending us appropriate notice.

In such a case, or if you would like further information about any recent changes made, please send your request to [email protected] and include “Information about Changes” in the subject line.