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Text Content

PRIVACY POLICY

UPDATED AND EFFECTIVE AS OF AUGUST 21, 2018.

ABCya.com is a teacher-created website brought to you by ABCya.com LLC ("ABCya")
that provides fun and educational games for kids to use under the guidance of
their parents and teachers. In this policy, we refer to our visitors younger
than age 13 as "Children." We provide this privacy policy to inform parents and
other users about our privacy practices for ABCya.com, our ABCya Games mobile
app, and any other ABCya online service that links to this Privacy Policy (the
"Platform"), as required by the Children's Online Privacy Protection Act
("COPPA"). Note that this Privacy Policy does not cover information collected
offline or through ABCya mobile apps that post a separate privacy policy.

Please review our full privacy policy below - but here are some key points to
know:

 * The Platform does not require Children to provide their name, address, or
   other contact information in order to play games. We, and third-party service
   providers, may automatically collect IP address and similar device
   identifiers from Platform visitors - but only for analytical and other
   internal-operations purposes.
 * The Platform does collect personal information from parents, teachers, and
   other adults (for example, if you subscribe to a paid account).
 * Unless you purchase an ad-free subscription, we have advertisements on the
   Platform, which are served by third-party companies. However, these ads are
   not targeted to a specific user. (We use only contextual advertising methods
   and not interest-based advertising methods).

In addition to this privacy policy, please review our Terms of Use, which govern
your use of the Platform, and our Payment Terms, which contain additional terms
applicable to paid subscriptions.

This Privacy Policy explains:
WHAT INFORMATION DOES ABCYA COLLECT AND HOW DO WE USE IT?
arrowTip

ABCya collects "Personal Information" which is information that could reasonably
be used to contact you or to identify you as specific person (for example, first
and last name, mailing address, email address, or telephone number), and other
information, some of which we collect automatically when you visit the Platform.

Personal Information

The Platform does not generally collect name, address, or other contact
information from Children, other than the limited circumstances set forth below.
However, we, and our third-party service providers, may collect a "Device
Identifier" associated with the computer, mobile phone or other device used to
access the Platform (for example, an IP address). These Device Identifiers are
considered Personal Information for Children. We, and our third-party service
providers, use Device Identifier information solely to support internal
operations, including operating Platform features and serving contextual ads.

The Platform may occasionally collect a Child's first name and online contact
information (typically, an e-mail address) solely for the following purposes:

- For one-time use of that information. For example, we may answer a question
submitted through the Platform or allow a sweepstakes entry. Once we have
responded or contacted the Child one time, we delete the online contact
information and will not use it to re-contact the Child;

- OR

- For the sole purpose of: protecting the security or integrity of the Platform;
taking precautions against liability; responding to judicial process; or
providing information to law enforcement agencies or for an investigation on a
matter related to public safety.

Additionally, in some instances a game may request that a user provide a name
(e.g., to identify a particular player in a multi-player game). In those
instances, the name provided is only stored locally on the user's device and not
collected by us.

Please note that we will not condition a Child's participation in a Platform
activity on the Child's disclosing more than is reasonably necessary to
participate in such activity. We use Personal Information only for the purpose
that it was provided and for internal purposes.

In some cases, we will collect Personal Information from a parent, teacher, or
other adult. We use information collected from adults:

- to process transactions and provide our products and services;

- to provide information, products, or services that we believe will interest
you or you have agreed to receive, including special offers from us and other
companies;

- to contact you regarding your account, our policies or your use of the
Platform;

- to improve our products and services and for our internal business purposes;
and

- for other purposes disclosed at the time you provide your information, with
your consent, and as described in this Privacy Policy.

Other Information

When you use the Platform, we (and our third-party service providers) may
automatically or passively collect certain "Usage Information," such as the
browser and operating system you are using, information on how you arrived at
the Platform, and all of the areas within our Platform that you visit. We may
use Usage Information for a variety of purposes, including enhancing or
otherwise improving the Platform and our products and services.

DOES THE PLATFORM USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
arrowTip

We, and our third-party service providers, may use the following or similar
technologies to collect Usage Information and Device Identifier:

Cookies & Local Storage. A cookie is a data file placed on your computer or
other device when you visit the Platform. Certain web browsers and add-ons we
utilize may provide additional local data storage mechanisms that are used in a
manner similar to cookies. Cookies and other local storage may be used for
various purposes, such as supporting game play, enabling Platform features, and
similar operational purposes. If you choose to disable cookies or to adjust
privacy settings on your device, some features of the Platform may not function
properly.

Web Beacons. We and our third-party service providers may use web beacons (small
graphic images or other web programming code, also known as "1x1 GIFs" or "clear
GIFs") and similar technologies. Web beacons or similar technologies may be used
for a number of purposes, including counting visitors and monitoring how users
navigate the Platform.

Embedded Scripts. An embedded script is programming code that is designed to
collect information about your interactions with the Platform, such as the links
you click on. The code is temporarily downloaded onto your device, is active
only while you are connected to the Platform, and is deactivated or deleted
thereafter.

HOW DOES ABCYA SHARE COLLECTED INFORMATION?
arrowTip

Children

ABCya does not disclose Children's Personal Information to third parties, except
with regard to the safety and security of the Platform as discussed above, and
to service providers who provide support for the internal operations of the
Platform and who do not disclose or use the Personal Information for any other
purpose. These service providers provide support services, such as hosting the
Platform and operating its features, or performing other administrative
services. ABCya may provide these companies with access to Children's Personal
Information so that they can perform services on our behalf. These service
providers have agreed to keep Personal Information they obtain from ABCya
confidential and secure.

Adults

With regard to Parents, teachers, or other adults who have provided information
in connection with a paid subscription, we may disclose such information
(including Personal Information) with your consent, as otherwise described in
this Privacy Policy, and in the following limited circumstances:

- Other Third Party Service Providers. In addition to those third-party service
providers described above, we may provide information collected from adult users
of the Platform to other service providers so that they can perform services on
our behalf, such as processing transactions, addressing customer service
inquiries, and sending email or other communications. In some instances, you may
provide your Personal Information directly to an identified third party through
a widget or other third party-hosted feature on the Platform, such as when
providing payment information during the subscription process.

- Administrative or Legal Reasons. We may also disclose information to third
parties: (i) where, in our opinion, such disclosure is required by law
(including to respond to a subpoena); (ii) at the request of governmental
authorities conducting an investigation; or (iii) to protect and/or defend
policies applicable to the Platform or to protect ourselves or any other
individual or entity.

- Business Transfers. We may also disclose information, including Personal
Information: (i) to a subsequent owner, co-owner or operator of the Platform or
(ii) in connection with a corporate merger, consolidation, restructuring,
bankruptcy, the sale of any ABCya ownership interest or asset, or other
corporate change, including, during the course of any due diligence process.

DOES THE PLATFORM USE THIRD-PARTY ANALYTICS PROVIDERS AND AD SERVERS?
arrowTip

ABCya works with advertising companies, analytics providers, and other service
providers to serve advertisements on the Platform, to provide us with
information regarding Platform traffic, and to serve our advertisements
elsewhere online. Our service providers may set and access their own tracking
technologies on your device. They may collect or we may give them access to your
Device Identifier and Usage Information, provided that your Device Identifier
will be used only to support internal operations. We only allow contextual
advertising on our Platform. (You will not see ads targeted to you as a specific
user).

ARE THERE THIRD-PARTY LINKS ON THE PLATFORM?
arrowTip

Certain content on the Platform may be hosted and served by third parties. In
addition, the Platform may contain links to third-party web sites that we do not
control. We are not responsible for the privacy or data collection practices of
any third party.

WHAT RIGHTS DO PARENTS HAVE?
arrowTip

Parents have the right to review and request that ABCya delete any Personal
Information that the Platform has collected and retained about their Child. If
you would like to request that ABCya delete any Personal Information we may have
about your Child (such as first name and contact information prior to the
Platform's one-time use) or if you would like to request that the Platform make
no further collection of Personal Information from your Child, please contact
ABCya at support (at) abcya (dot) com.

WILL MY INFORMATION TRANSFER TO THE UNITED STATES?
arrowTip

If you do not live in the United States, know that information we collect will
be transferred to and processed in the United States. By using the Platform, you
consent to the collection, transfer, processing and storage of your information
in the United States, a jurisdiction in which the privacy laws may not be as
comprehensive as those in the country where you reside and/or are a citizen.

WHAT STEPS DOES ABCYA TAKE TO SECURE MY PERSONAL INFORMATION?
arrowTip

ABCya takes reasonable steps to protect the confidentiality and security of
Personal Information collected from Platform users. We also take reasonable
steps to release Children's Personal Information, if any, only to service
providers and third parties who are capable of and have agreed to maintain the
confidentiality and security of that information.

If personal information under our control is compromised as a result of a breach
of security, we will take reasonable steps to investigate the situation and take
all steps required by applicable laws and regulations and our agreements with
any affected Schools.

HOW WILL YOU NOTIFY ME IF THIS PRIVACY POLICY CHANGES?
arrowTip

ABCya may update this Privacy Policy at any time and any changes will be
effective upon posting (unless otherwise specified). We will provide notice on
the Platform and we may also provide notice in other ways, such as sending you
an email. Your continued use of the Platform after the effective date of the
revised Privacy Policy (or such other act as specified in the revised Privacy
Policy) will constitute your consent. However, we will obtain consent (opt-in or
opt-out for adults and prior parental consent for Children) before using or
disclosing Personal Information in a manner materially different from the
Privacy Policy posted at the time of collection and any prior parental consent
received.

HOW DO I CONTACT ABCYA?
arrowTip

ABCya.com LLC is the operator of this Platform and questions regarding this
Privacy Policy and use of Personal Information should be directed to ABCya.com
through any of the following methods:

Mailing address: ABCya.com LLC
4 Richmond Sq Suite 55
Providence, Rhode Island 02906

Email: support (at) abcya (dot) com

Call toll-free (855) 250-9249

INFORMATION FOR RESIDENTS OF THE EUROPEAN UNION AND THE EUROPEAN ECONOMIC AREA
arrowTip

This section of the Privacy Policy applies only if you use our Sites or Apps, on
iTunes, Google Play, Amazon and Microsoft, covered by the Privacy Policy from a
country in the European Union or another member state of the European Economic
Area (“EEA”), and it supplements the information in the Privacy Policy.

ABCya.com, L.L.C. is the data controller for processing of information defined
as personal data under applicable data protection law (“Personal Data”).

LEGAL BASIS FOR DATA PROCESSING

We process Personal Data for the purposes set out in the Privacy Policy. Our
legal bases to process Personal Data include processing that is necessary for
the performance of a contract between us, in the case of subscription users (for
example, to provide you with services you request and to identify and
authenticate you so you may use the website); necessary to comply with legal
requirements and applicable accounting standards and to make mandatory
disclosures to law enforcement and regulatory authorities; necessary for our
legitimate interests (for example, to manage our relationship with you, to
improve the website and our services, to protect our property and safeguard
against fraud and malware, to make or defend legal claims); and based on consent
by our customers (for example, to communicate with you about our products and
services and provide you with marketing information). Where we process your
Personal Data with your consent, you may subsequently withdraw consent at any
time by contacting us (using the contact instructions below), without affecting
the lawfulness of processing based on consent before its withdrawal.

EU DATA SUBJECT RIGHTS

The EU General Data Protection Regulation (GDPR) and other applicable data
protection laws provide certain rights for individual data subjects (“EU Data
Subject Rights”). You may decline to share certain Personal Data with us, in
which case we may not be able to provide some of the features and functionality
of our services. These rights include, in accordance with applicable law, the
rights to access or rectify Personal Data, object to or restrict further
processing, or request the erasure of Personal Data or, where feasible, to have
it moved to a new service provider (“data portability”). You must be 16 years or
older to make a request or else have your parent contact us on your behalf.

Normally, we can respond to requests for access within 48 hours. If we cannot
honor your request concerning Data Subject Rights within 30 days, we will inform
you and provide an explanation. When technically feasible, at your request, we
will provide your Personal Data to you or transmit it directly to another
controller.



We retain your Personal Data while you have an account with us and while you are
using our services or continuing to visit our Site. We will retain your Personal
Data for as long as it is reasonably necessary for the purposes set out in the
Privacy Policy, considering the time period reasonably necessary to: provide the
services to you; exercise the choices and rights you have requested; comply with
our contractual obligations; enforce our terms for use of the services; and
comply with legal and regulatory requirements.

If you have any unresolved privacy concern that we have not addressed
satisfactorily after contacting us, you have the right to contact the relevant
national data protection supervisory authority and lodge a complaint.

CHILDREN

Our Privacy Policy addresses the information we collect from children, how we
use it and parental access. Note that we do not knowingly sell goods or services
to children younger than age 16.

CONTACT US

For all EU Data Subject Rights requests, please contact us at support@abcya.com.
You must put the statement "Your EU Data Subject Rights" in the subject field of
your request and include in the request the name of the Services with respect to
which you are requesting the information, as well as your contact information.


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