GAME-U, LLC PRIVACY POLICY

Last Updated: 2026-07-15

Game-U, LLC ("Game-U" or "we," "us" or "our") is committed to protecting your privacy. This Privacy Policy ("Policy") explains what Personal Information we collect in providing our student-facing learning services, including classes, programs, activities, and similar services, together with any webpages, tools, features, or functionality used to access or deliver those services (our "Services"), and our public-facing marketing and informational websites, including, without limitation, www.game-u.com, along with the features, functionalities, applications, and browser extensions available through our websites (collectively, our "Websites"), and how we use, disclose, and safeguard that information.

Please read this Policy carefully. If you are under the age of 18, please review it with a parent or guardian so you both understand how Game-U handles your Personal Information. If you have any questions about how we collect, use, protect, or disclose your Personal Information in connection with our Services and Websites, please contact us by email at support@game-u.com.

GAME-U SERVICES FOR INDIVIDUALS AND SCHOOLS

Game-U offers its Services in two ways: directly to individuals ("Individual Services") and through schools or school districts (generally, "Schools") under institutional agreements ("School Services"). Our privacy practices are tailored to each context, as described in this Policy.

In this Policy, the Personal Information we collect, receive, and use in connection with: (1) the Individual Services is referred to as "Individual Personal Information"; and (2) the School Services is referred to as "Student Personal Information".

For School Services, our agreement with a particular School, including any applicable Student Data Privacy Addendum (DPA), governs how we use, disclose, retain, and protect the applicable Student Personal Information. A copy of our template DPA is available at DPA. However, please be aware that our DPA with a particular school may differ from our template DPA. The School's authorized personnel can access Student Personal Information through our School Services to support instruction and track progress, and their use of that data is governed by the School's policies. We are not responsible for, nor do we have control over, how a School uses or discloses Student Personal Information.

WHAT IS PERSONAL INFORMATION?

When we refer to "Personal Information" in this Policy, we mean information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a specific person. This might be information that directly identifies someone, such as their name, or it may be information that identifies someone only when combined with other information available to us. Personal Information also includes "Personal Information" as defined in the Children's Online Privacy Protection Act ("COPPA") and "Personally Identifiable Information" as defined in the Family Educational Rights and Privacy Act ("FERPA"). However, Personal Information does not include information that is publicly available through government records.

CHILDREN'S PRIVACY

We design our Services to comply with all applicable laws, including COPPA and FERPA. We tailor our privacy practices based on the age of our users. For additional information about our practices for collecting, using, and disclosing Personal Information from teens and children, please review our Children's Privacy & Student Data page, available at Children's Privacy Policy.

Individual Services

With respect to our Individual Services, for any student who is under 18, we provide notices of our privacy practices to, and collect verifiable parental consent from, that student's parent or guardian before collecting or using that student's Individual Personal Information. Please note, where we receive Individual Personal Information from a student who is under 18 before obtaining verifiable parental consent from that student's parent or guardian (such as where a student attempts to sign up for the Individual Services on their own), we will not use that student's Individual Personal Information for any purpose other than providing notice of our privacy practices to, and attempting to obtain verifiable parental consent from, that student's parent or guardian.

School Services

For our School Services, we function as a "school official" under FERPA, which means we perform a service or function for which the School would otherwise use School employees. In this scenario, the School acts on behalf of a student's parent or guardian to provide consent to that student's use of our School Services. We rely on the School to obtain any required parental consent and to communicate to parents and guardians how Student Personal Information is collected, received, and used in connection with the School Services.

We treat Student Personal Information as part of the student's education record, and we use it only for authorized educational purposes of providing and supporting the School's program, including improving our educational Services, and for related legal or safety needs (consistent with our role as a "school official" under FERPA). Without limiting anything in this Policy, Game-U does not use Student Personal Information for any commercial purposes (such as marketing or advertising).

PERSONAL INFORMATION WE COLLECT

This section provides a general overview of the categories of Personal Information we collect from or about our users (e.g., students, parents/guardians, educators, Website visitors, etc.) and identifies the specific categories of Personal Information we collect in individual contexts.

Categories of Personal Information We Collect

Depending on how you access, use, or otherwise interact with our Websites or Services, we may collect the following categories of Personal Information about you.

• Identifiers and Contact Information – name, email address, mailing address, telephone number, user ID, password, unique personal identifier, online identifier, IP address and other similar information.
• Demographic Information – age, date of birth, gender, and other similar information.
• Internet and Network Activity Information – certain technical data about access to, use of, and interaction with our Services and Websites that are automatically collected through cookies, pixels, and other technologies. This category includes information such as device and browser details (operating system, browser type, language settings, device identifiers), IP address and general location (city, state, or ZIP code associated with an IP address), pages or learning modules visited, time spent on pages, navigation paths and referral URLs, features or content interacted with, timestamps of activities, and other similar information. Please note, as further described in the Cookies and Tracking Technologies, the use of any advertising/marketing-related trackers is limited to our adult-oriented public Websites and are not used in student learning environments.
• Coursework Information – coursework and content created by a student, participation in classes, time spent using or otherwise interacting with the Services and other similar information associated with a student's use or interaction with our Services.
• Skills Information – aptitude, skills, interests, together with other interest-based information that is provided to us or is created through or in connection with the use or interaction with our Services and other information provided to, or received from, students via our Services.
• Educational Information – school, grade level, student ID, parent or guardian ID and other similar information.
• Commercial Information – records and history of Services purchased or considered, transaction data, payment information and other similar information.
• Communication Content – content of communications and interactions we have with an individual, such as emails, chat messages, support requests, feedback, and inquiry form submissions.
• Audio and Video Recordings – class recordings, recordings of customer service calls and other similar information. We will notify participants when class sessions are being recorded.

Categories of Personal Information Collected in Particular Contexts

The following table identifies the categories of Personal Information described above that we collect in connection with our School Services, Individual Services, and our Websites.

Please note, as used in this Policy, the term "Websites" only refers to our public-facing marketing and informational websites and does not include any webpages or tools used to access or deliver our Services.

SOURCES OF PERSONAL INFORMATION

We collect Personal Information from the following categories of sources, depending on how you access, use, or interact with our Services or Websites.

• Directly from You or Your Representatives – We receive Personal Information directly from you when you use our Services or Websites or interact with us. For example, you (or, for minors, your parent/guardian) may provide contact and account details during registration, or you might submit information through a contact form, sign-up page, or support request. We collect this information for purposes such as creating and managing accounts, enrolling you in programs, communicating with you, and providing the Services or information you request. Additionally, sometimes others acting on your behalf or at your request, such as a parent, guardian, or teacher, provide your Personal Information to us for these same purposes.
• Schools – If you use our School Services, your School may provide Personal Information about students (and their parents/guardians) to us. For example, a School might send class rosters or student account details (names, school email address, student IDs, grade levels, parent contact information, etc.) to us to facilitate account creation, enrollment in classes, and management of the educational program. We collect this information from Schools for the purpose of providing and supporting the School Services for those students on the School's behalf.
• Automatically from Your Use of Services or Websites – As you interact with our Services or Websites, we use technology to automatically gather certain Personal Information. For instance, our systems collect device and usage data (like IP address, browser type, pages visited, etc.) as you use the Services or browse our Websites. We collect this information to make our online Services and Websites function correctly, to maintain security, to analyze usage patterns, and to improve performance and user experience. To learn more about your options to limit the data collected while using our Websites, see the Your Consumer Data Choices section below.
• Payment Processors – We use PCI-compliant payment processors to facilitate payment, on our behalf, when you purchase our Individual Services. We have contracted with the payment processors to ensure they protect and limit the use of your Personal Information. You can find more about how our payment processors handle your Personal Information by visiting https://squareup.com/us/en/legal/general/privacy or https://stripe.com/privacy. The payment processors provide your contact and transaction information along with the last four numbers of your card to us so we can confirm your purchase and payment. We will keep a record of this information.
• Service Providers – We work with various service providers who support our operations (e.g., companies that host our Websites and Services, provide customer support tools, facilitate communications, or assist with technical support). These service providers may collect or process Personal Information on our behalf and then provide certain data back to us as needed. For example, a customer support platform might collect your support inquiries and share them with us so we can respond; or a cloud hosting provider may store our databases and make the information accessible to us. We receive Personal Information from these service providers solely for the purpose of operating and supporting our Services and Websites.
• Analytics, Marketing, and Advertising Providers – We may receive information from third party analytics or advertising partners related to users' interactions with our Websites or online ads. We do not receive any Student Personal Information or Individual Personal Information from these providers. For example, analytics providers may provide aggregated data about Website traffic or usage, and advertising providers might inform us which audiences or visitors have viewed or interacted with our online ads. We use information from these providers to understand our audience and improve our marketing effectiveness.
• Other Individuals or Third Parties – Occasionally, we receive Personal Information from other individuals or organizations not already described above. For instance, a person who wants to refer you to our Services (such as a friend or family member) might provide your name and contact information so that we can reach out to you. In such cases, we collect and use the Personal Information for the purpose it was provided to us (e.g., to make the requested contact or offer our Services to the referred individual).

HOW WE USE PERSONAL INFORMATION

Depending on how you access, use or interact with our Services or Websites, we may, where permitted and in compliance with applicable laws, use your Personal Information for the purposes described in this section. We do not sell Personal Information to third parties for monetary compensation.

Uses of Student Personal Information

We use Student Personal Information to provide a safe, effective educational experience and for related business operations necessary to run and improve our Services, all in compliance with COPPA and FERPA. Specifically, we use Student Personal Information to:

• Provide and support the School Services. We use Student Personal Information to deliver class content, tailor lessons to a student's level, track their progress, enable teachers to manage classroom activities, and as otherwise necessary to fulfill our contractual obligations to the School and support the student's education. This may include creating accounts, recording assignments and scores, and providing feedback.
• Operate, maintain, and secure the School Services. We use Student Personal Information as needed for internal operations, such as ensuring the School Services work correctly, fixing bugs, performing analytics to improve performance, and protecting the security of the School Services. This can include using technical information, such as device identifiers or cookies, in ways that COPPA allows for the support of internal operations (e.g., maintaining functionality, network security, or personalization). Persistent identifiers (such as device identifiers, cookies, and pixel tags) that we collect in student learning environments are treated as Student Personal Information. We use them only for permitted internal operations — such as maintaining functionality, security, and personalization — as allowed under COPPA, and never for targeted advertising, profiling, or marketing.
• Communicate about educational matters. We may use Student Personal information to send updates or reports to parents, guardians, or teachers. This may include sharing progress reports, notifying of changes in the School Services, or responding to a teacher's inquiry. We direct communications about students either through their School or to their parent/guardian, consistent with COPPA's parental consent and School communication requirements. We do not send promotional content to student users. Any new program information is sent only to adult users (like parents or Schools) per their preferences, not to students.
• Improve our Services and inform our strategies. We analyze Student Personal Information (often in aggregate or de-identified form) to understand our student population and how our School Services are used. This helps us identify what educational approaches work best, recognize trends in student engagement, and guide product development and business strategies (e.g., deciding what new features to build that benefit students and Schools). Importantly, these analyses do not identify individual students and we never use Student Personal information to profile students for commercial purposes or target them with advertising.
• Customer support and service quality. We use information from student interactions (e.g., support tickets or help chats initiated by teachers or parents/guardians on a student's behalf) to ensure we are providing high quality customer service. For instance, we may review support inquiries to improve our responses and train our team, always handling any Student Personal Information involved with strict confidentiality.
• Ensure legal and policy compliance. We may use Student Personal Information to enforce our terms (e.g., prevent misuse of educational tools), to comply with laws (e.g., using birthdates to confirm whether we need parental consent under COPPA), or to fulfill our obligations as a "school official" under FERPA (i.e., only handling student records as directed by the School for legitimate educational purposes).

We do not use Student Personal Information for any commercial marketing or advertising purposes. We do not sell, rent, or trade Student Personal Information and we do not build marketing profiles from Student Personal information. All the ways we use Student Personal Information are intended to directly support education, to run and improve our Services (internal operations), or to meet our legal and contractual obligations to students, their families, and Schools, consistent with COPPA and FERPA.

Uses of Individual Personal Information

We use Individual Personal Information, which may include the Personal Information of child users (with required parental consent for those under 13) as well as adult users. We use Individual Personal Information in several ways:

• Providing and fulfilling our Individual Services. We use Individual Personal Information to deliver the Individual Services you signed up for, including creating and managing your account or enrollment, scheduling classes or sessions, processing payments, sending confirmations, and otherwise performing our contractual obligations to you or your parent/guardian.
• Communication and customer support. We use Individual Personal Information to communicate with you or your parent/guardian. For example, we send service-related messages (e.g., reminders, class updates, invoices, or policy changes) and respond when you contact us for support or questions. For adult users (or parents/guardians of child users), we might also send optional promotional communications about new classes or special offers that could interest you. As further described in the Your Consumer Data Choices section of this Policy, you can opt-out of these marketing messages at any time. We do not send marketing or promotional communications to children, and any child's Individual Personal Information is not used for marketing purposes.
• Service improvement and analytics. We evaluate how users engage with our Individual Services to make them better. This means we might review aggregated data about class attendance, feature usage, or feedback to identify what's working and what needs improvement. We also look at user preferences and demographics, so we can tailor our content and develop business strategies that meet our users' needs. For example, understanding the ages and interests of our participants may inform what new classes we offer or how we improve our curriculum. Any in-depth analysis of usage patterns is done on de-identified data wherever possible.
• Internal operations and security. We use Individual Personal Information for routine business operations, including account administration, recordkeeping, audit and compliance, and quality control. For instance, we might keep records of enrollment to manage class sizes and teacher assignments, or use technical data and logs to ensure our Individual Services are secure and reliable. We also use Individual Personal Information to prevent fraud or unauthorized activity, and to comply with any obligations under applicable law.
• Business planning and legal compliance. In the course of running and growing our business, we might use Individual Personal Information to assess our performance and plan future strategies. This could involve analyzing trends in user enrollment or feedback to guide our decision making. Additionally, if we ever consider significant business changes (like mergers or acquisitions), we might use aggregated user data in evaluating those opportunities, always in compliance with privacy laws. And, as needed, we use Individual Personal Information to enforce our agreements and legal rights or address issues like fraud, safety, and compliance with laws or court orders.

Any children's Individual Personal Information collected or used in connection with our Individual Services are protected under COPPA, meaning we obtain parental consent and limit use to what is allowed by law, such as using children's Individual Personal Information only for our internal needs to provide and improve the Services.

Uses of Website Personal Information

We use the Personal Information we collect when you visit our public Websites ("Website Personal Information") to:

• Operate and improve the Websites. We use data such as your device type, IP address, and how you navigate our Websites to ensure our Websites function correctly, to troubleshoot and fix errors, and to improve the design and content of our Websites. For example, we may track which pages of our Websites are visited most often or how users find our Websites, and use this information to make our Websites easier to find and more useful. We also use cookies and similar technologies for these purposes, as allowed by law. Please see the Cookies and Tracking Technologies section below for more information.
• Respond to your requests. If you fill out a contact form, request information, or interact with our Websites (such as signing up for a newsletter or requesting a demo), we use the Website Personal Information you provide, such as your name and email address, to fulfill your request and communicate with you. This might include sending you the information you asked for or contacting you to follow up on your interest in our Services.
• Understand our audience and improve our offerings. As described in greater detail in the Cookies and Tracking Technologies section below, we analyze how visitors use our Websites by using analytics cookies and similar technologies. This helps us to understand the characteristics and preferences of our visitors so we can tailor our content and services accordingly. For example, we may learn what types of content are popular or which regions visitors to our Websites come from, and use that information to inform our marketing and business strategies. This analysis is mostly done on aggregated data that does not directly identify individuals.
• Marketing and advertising to adult users. We may use Website Personal Information to market our Services. For example, if you are an adult visitor, we might use cookies or third party advertising partners to show you relevant Game-U ads on other sites or to email you about new offerings, but only in accordance with applicable laws and your preferences. We do not serve targeted advertising on any parts of our Websites designed for children or students, and we do not knowingly use data from children's visits to our Websites for advertising purposes. Any advertising or analytics partners we use on our Websites are not permitted to use the data for their own purposes beyond providing services to us. Your options to limit these activities in your browser or via our Websites are described in the Your Consumer Data Choices section below.
• Security and legal compliance. We use information from our Websites to protect our rights, enforce terms applicable to the use of our Websites, prevent fraud, and comply with legal requirements. For example, we might use web logs to detect malicious activity or disclose necessary information if we are legally required to.

In summary, all Website Personal Information is used to operate and grow our online presence, serve our users, and support our business. We never sell Website Personal Information to third parties or use Website Personal Information to target children with marketing.

DISCLOSING PERSONAL INFORMATION TO THIRD PARTIES

As described in greater detail below, we limit our disclosures of Personal Information to what is necessary to operate our Services and Websites, comply with our legal obligations, or as you (or your parent/guardian or your School) direct or consent.

Disclosures of Student Personal Information

We do not disclose Student Personal Information to third parties except in the limited, carefully controlled ways described here. Any disclosure of Student Personal Information is intended to support the student's education or for safety and legal compliance, and never for advertising or marketing purposes. Specifically, we may disclose Student Personal Information:

• To the student's School and teachers. We disclose relevant Student Personal Information with the School and teachers responsible for that student's education, as needed to support instruction and school operations. For example, teachers and administrators can access their students' assignments, progress reports, and other educational records available through our School Services. We disclose this Student Personal Information as part of our role as a "school official" under FERPA, meaning we use Student Personal Information on behalf of and at the direction of the School, consistent with what FERPA permits for legitimate educational interests.
• As directed by the School. We will disclose Student Personal Information with third parties as instructed by the applicable School. For example, if a School chooses to integrate a third party educational app with our School Services and asks us to disclose Student Personal Information with the app provider, we will do so pursuant to the School's instruction and in accordance with privacy laws.
• To our service providers who operate on our behalf. We work with a limited number of trusted third party service providers who help us deliver and improve our educational Services, such as secure data hosting companies and technical support providers. These service providers may have access to Student Personal Information solely as necessary and applicable to the services they provide to us, and they are contractually obligated to protect it and not use it for any other purposes. For example, a service provider that hosts our databases may store Student Personal Information on our behalf, but are not permitted to view or use that data for their own purposes.
• For legal and safety reasons. In certain cases, we may be required (or consider it appropriate) to disclose Student Personal Information to comply with the law or protect people's safety. For example, we might disclose Student Personal Information in response to a court order or if needed to address a threat to health or safety at a School.
• In a business transfer. If we evaluate or go through a corporate transaction such as a merger, acquisition, reorganization, divestiture, or sale of all or part of our assets (including during bankruptcy or similar proceedings), Student Personal Information may be disclosed or transferred to the organizations involved as part of that process. In such an event, we will ensure that any successor organization continues to protect Student Personal Information in accordance with this Policy (or a policy that is at least as protective), and we will notify Schools as required by law.

Disclosures of Individual Personal Information

For Individual Personal Information, we may disclose it to third parties in the following ways, consistent with applicable privacy laws (including COPPA for children):

• With service providers who work for us. We disclose Individual Personal Information with third party companies that provide services to us, such as payment processing, data hosting, analytics, email communications, customer support, and similar functions. These service providers are only provided the Individual Personal Information necessary for the services they provide, and they are legally bound to keep Individual Personal Information confidential and to only use it for the purposes of providing services to us.
• With parents/guardians (for child users). For children enrolled in our Individual Services, their parent or guardian will have access to their Individual Personal Information for various purposes, such as reviewing their child's progress or to manage their child's account, as part of parental control and consent under COPPA. We may also share updates about the child's activities directly with the parent or guardian (per their preferences). We will also disclose a child's Individual Personal Information to a parent or guardian pursuant to a verified parental request.
• With your consent or at your request. If you are an adult user (or a parent/guardian acting for your child), we will disclose your Individual Personal Information when you ask us to and consent to it. For example, if you want us to publish your testimonial or project on our Websites, or if you connect your account with a third party service, we will disclose Individual Personal Information as needed to fulfill those requests and in accordance with your consent.
• With marketing or advertising partners (for adult users). If you are an adult user, we may disclose some of your Individual Personal Information (such as an email hash or device identifier) to marketing and advertising partners to help promote our Services to you or others like you, but only with your consent or as allowed by law. For example, we might use a secure service to send promotional emails or work with an advertising platform to show adult users (or others with similar interests) relevant Game-U ads on other sites. As described in greater detail in the Your Consumer Data Choices section of this Policy, we provide a variety of ways that adult users can use to opt-out or otherwise limit the use of their Individual Personal Information for these purposes. We never disclose children's Individual Personal Information for advertising purposes.
• For legal, compliance, or safety. We may disclose Individual Personal Information if we believe it is necessary to do so to comply with laws or legal processes, to respond to lawful requests (such as a subpoena), or to protect the rights, safety, and property of Game-U, our users, or others. For instance, if required by authorities for a legal investigation, to enforce our terms, or prevent fraud, we may disclose relevant Individual Personal Information as needed.
• During business transfers or transactions. If Game-U is involved in or undergoes a business transaction (e.g., a merger, acquisition, reorganization, sale of assets, bankruptcy, or similar event) we may need to disclose or transfer Individual Personal Information as part of that process. Any party that receives Individual Personal Information in such a transaction will be required to continue protecting it consistent with this Policy (or a policy with comparable protections). We will also provide notifications and choices as required by law if your Individual Personal Information becomes subject to a new privacy policy due to a transaction.

Disclosures of Website Personal Information

We may disclose Website Personal Information in order to operate our business, market our Services, and comply with legal obligations, as described below. The disclosures of Website Personal Information described in this section do not apply to Student Personal Information or Individual Personal Information, since our Websites are not intended for student use. In any event, if any child's Personal Information is collected via our Websites, we handle it with in accordance with COPPA and do not use it for marketing or advertising purpose. Website Personal Information may be disclosed:

• To service providers who help operate our Websites. We disclose Website Personal Information with service providers who assist us in operating and improving our Websites (e.g., website hosting companies, data analytics providers, customer support tools, etc.). These service providers are permitted to process Website Personal Information only for our business purposes and under confidentiality obligations.
• To analytics and advertising partners (for adult users). As more fully described in the Cookies and Tracking Technologies section below, we may allow certain third parties to collect or receive information about visitors to our Websites (e.g., cookie identifiers, browsing data, and device information) to help us analyze traffic on our Websites or display ads for our Services on other sites. For example, we might use analytics technologies to understand usage patterns applicable to our Websites or work with advertising platforms to reach people who have shown interest in our Services. We do not permit this kind of data collection or disclosure for known child users, Student Personal Information, or children's Individual Personal Information, and we exclude known children from such data collection and disclosures. Please see the Your Consumer Data Choices section below for information about how you can opt-out of this kind of data collection or disclosure.
• If you post or direct us to share content. If you make a public post on our Websites (e.g., a testimonial or comment) or interact with our social media channels, any information you provide might be visible to others by your own action. Similarly, if you ask us to disclose your Website Personal Information to a third party, we will do so with your consent.
• For legal compliance or to protect rights and safety. We may disclose Website Personal Information when we believe we must do so to comply with applicable law or valid legal process, or to protect our rights, property, and users. For example, we might provide logs to law enforcement if required, or disclose Website Personal Information to investigate and prevent security issues or fraud.
• In the event of a business transaction. If we consider or take part in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our business, Website Personal Information may be disclosed or transferred as part of that process. If this happens, we will ensure your Website Personal Information remains protected by this Policy (or a policy with similar protections). We will also provide notifications and choices as required by law if your Website Personal Information becomes subject to a new privacy policy due to a transaction.

RETENTION OF YOUR PERSONAL INFORMATION

We retain Personal Information only for as long as necessary to fulfill the purposes described in this Policy or as required by law.

Retention of Student Personal Information

For Student Personal Information, we retain the information only for as long as it serves educational purposes or as required by law or our agreements with the applicable School. We will return or delete Student Personal Information according to our contract with the School and any instructions from the School. If a School does not provide specific instructions, we will still ensure that Student Personal Information is securely deleted or de-identified within a reasonable period (typically no longer than 90 days) after it is no longer needed for educational purposes.

Retention of Individual Personal Information and Website Personal Information

We retain Individual Personal Information and Website Personal Information only as long as we have a legitimate business purpose to keep it, such as to provide our Individual Services to you; ensure the security and integrity of our Services and Website; and satisfy any legal, regulatory, tax, accounting, or reporting requirements.

To determine the appropriate retention period for individual categories of Individual Personal Information and Website Personal Information we collect, we consider the nature and sensitivity of the Individual Personal Information or Website Personal Information; the potential risk of harm from unauthorized use of the Individual Personal Information or Website Personal Information; the purposes for which we process that Individual Personal Information or Website Personal Information and whether we can fulfill those purposes through other means; and applicable legal, regulatory, tax, accounting, reporting, and other requirements.

DE-IDENTIFIED/AGGREGATED DATA

We may de-identify or aggregate Personal Information so that it no longer identifies any individual. Once we do this, the information is no longer considered Personal Information. We may use de-identified or aggregated data for lawful analysis, research, and product improvement efforts, including improving our Services. We will not attempt to reverse this process or attempt to re-identify information that we have anonymized or de-identified.

COOKIES AND TRACKING TECHNOLOGIES

We use cookies, pixel tags, and similar technologies (collectively, "AdTech") on our public Websites to gather information that helps us enhance user experience and our business operations, improve functionality, analyze usage, and assist with marketing to adult audiences.

Our public Websites are intended for adult visitors, such as parents and educators, and the AdTech described below is only used on those Websites. For clarity, the AdTech described below is not used in our Services.

The AdTech we use includes cookies, web beacons, pixel tags and other technologies. Cookies include small files, such as text files, which are saved onto your computer or device when you use our Websites. These can either be "session" cookies or "persistent" cookies. Session cookies exist only for so long as you are visiting a website and are typically deleted when you exit your web browser. Persistent cookies remain on your computer or device until their predetermined expiration date unless they are deleted before then. Additionally, each time you visit a website that has implemented a persistent cookie, that persistent cookie is renewed and remains active until its predetermined expiration date unless deleted before then.

• Analytics AdTech – We use certain AdTech on our Websites to learn more about how visitors navigate and view content on our Websites ("Analytics AdTech"). Analytics AdTech provides us with analytical information that we use to improve our Websites, make sure they are easy to use, and conduct our business operations. The Analytics AdTech we use on our Websites includes the following:

  • Hotjar – We use Hotjar, a third-party analytics and session replay technology, to better understand how users interact with our Websites and to improve the overall user experience. Hotjar records information such as clicks, taps, scrolling behavior, and other interactions with our Websites. This technology helps us identify usability issues and optimize our Websites. Hotjar uses cookies and other AdTech to collect data on user behavior and devices. This includes IP addresses, unique device identifiers, browser information, geographic location (country only) and your preferred language. Hotjar stores this information on our behalf in a pseudonymized user profile. You can choose to prevent Hotjar from collecting your information at any time by following the instructions provided here. For more information about Hotjar's privacy practices, please review their Privacy Policy.
  • New Relic – We use New Relic's browser monitoring service to track the performance of our Websites in real time. New Relic collects information about how you navigate our Websites and the time you spend on our Websites. New Relic will collect information about your browser, device and your session on our Websites. New Relic is our service provider and is contractually obligated to use any Personal Information only at our direction and to protect the privacy and security of Personal Information. To learn more about the Personal Information New Relic collects, see the New Relic Services Data Privacy Notice.
  • Cloudflare Insights – We use Cloudflare Insights, a privacy‑focused analytics and performance monitoring service provided by Cloudflare. Cloudflare may collect information such as IP addresses, system configuration data, device and browser characteristics, and information about how you interact with our Websites. This data helps us understand traffic patterns, detect performance issues, and maintain the security and reliability of our Websites. For more information on how Cloudflare collects and processes data, please review the Cloudflare Privacy Policy.

• Targeted Advertising AdTech – We use certain AdTech on our Websites that enable us, ad networks, and other third parties to serve customized email and internet-based advertisements to Website visitors ("Targeted Advertising AdTech"). Targeted Advertising AdTech is used to serve ads based on your prior visits to our Websites and your other internet activity, such as your visits to other websites. Ad networks and other third parties may place and store additional AdTech on the devices you use to access our Websites and collect information from visitors to our Websites (excluding Student Personal Information) including your browsing behavior, referring sites, and your response to advertisements. The Targeted Advertising AdTech we use on our Websites includes the following:

  • Google Analytics and Google Advertising Features – We use Google Analytics to collect and process information about your use of our Websites. Google sets AdTech on your browser or device, and then your browser or device will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Websites. We have enabled and implemented the following Google Analytics Advertising features: Google Tag, Google Marketing Platform, and Google Signals. To prevent your information from being used by Google Analytics and its advertising features, follow the instructions to download and install the Google Analytics Opt-Out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout, for each browser or device you use. Using the Google Analytics Opt-Out Browser Add-on will not prevent us from using other AdTech and will not prevent data from being sent to our Websites or to Google. Opting out will not affect your use of our Websites.

Google Signals is a feature in Google Analytics 4 (GA4) that uses data from Google's ecosystem (such as Google Search, Gmail, YouTube, etc.) to identify and track users across devices when they are signed into their Google accounts and have Ads Personalization enabled. Google Signals utilizes information collected through Google's cookie-based systems for tracking and personalization when users are signed in and have Ads Personalization enabled. The information collected by Google Signals will be transmitted directly to and stored by Google. This information will be used for cross-device reporting, targeted advertising based on user behavior across devices, and to enable more precise targeted advertising efforts.

For more information on how Google uses Personal Information, review the Google Privacy Policy. You can also review Google's disclosures about how it uses data when you use Google's partners' websites or apps, available at https://policies.google.com/technologies/partner-sites.

YOUR CONSUMER DATA CHOICES

We offer several ways for you to control how your Personal Information is collected, used or disclosed:

• Update your Personal Information – You can update your Personal Information by contacting us using the information in the Contact Us section below.

• Opting Out of Email Marketing – You can opt-out of receiving marketing and other promotional email communications we send you by following the unsubscribe instructions contained in most email messages from us. Your unsubscribe request or email preference changes will be processed promptly, though this process may take several days. During that processing period, you may receive additional marketing and other promotional emails from us. Please note, opting out of these communications will only apply to marketing and other promotional emails and will not apply to any email or other communications we send to you for non-marketing purposes, including, but not limited to, emails and other communications about your access to or use of the Services.

• Opting Out of Targeted Advertising – If you wish to limit third-party advertising, you can visit the National Advertising Initiative Consumer Opt-Out page and the Digital Advertising Alliance's Consumer Choice Tool. In addition, the electronic device you use to visit our Websites may offer additional privacy settings; please see the device settings for details. Please note that even if you opt out of receiving interest-based advertising, you will still receive advertisements, but they will be more general in nature.

• Update Your Browser Settings – The Options/Settings section of most internet browsers will tell you how to manage cookies and other technologies that may be uploaded to your device, including how to disable such technologies. You can disable our cookies, or all cookies, through your browser settings, but please note, disabling cookies may impact some of the features of our Websites and prevent them from operating as intended. You can learn more about cookies, including how to see what cookies have been uploaded to your device and how to manage and delete them, by visiting All About Cookies.

• User Access and Consumer Rights – Users (or their parents or guardians) of our Services may have the legal right (including under COPPA and FERPA) to access, correct, export or delete certain of their own information or content, or to make certain choices. To make a request:

  • for Individual Services, please contact us at support@game-u.com; and
  • for School Services, please contact the applicable School. We will help them provide the requested access or make appropriate corrections. If we receive such requests directly, we will refer those inquiries to the appropriate School to the extent required or permitted by applicable law or agreement.

• Additional Rights for Residents of California – If you are a California resident, under California's Shine the Light Law (California Civil Code Section 1798.83) you have the right to request the following information regarding our disclosure of your Personal Information to third parties for direct marketing purposes: (1) the categories of Personal Information we have disclosed to third parties for their direct marketing purposes during the preceding calendar year; (2) the names and addresses of the third parties that received the Personal Information; and (3) if the nature of the third party's business cannot be determined from their name, examples of the products or services they marketed. This information may be provided in a standardized form that is not specific to you. You are permitted to obtain this information from us once a year, free of charge. To make such a request, please submit your request in writing to:

  Game-U, LLC
  Attn: CA Privacy Rights Request
  203 Main Street, Suite 300
  Flemington, NJ 08822

THIRD PARTY WEBSITES AND SOCIAL MEDIA

Our Websites may link to websites we do not own or control. We are not responsible for the privacy policies or practices of any third parties or any third party websites. This Policy does not apply to any third party website or to any Personal Information that you may provide to third parties. You should read the privacy policy for each website you visit.

We are active on social media, including Facebook, TikTok, YouTube, X (previously known as Twitter), Instagram, and LinkedIn ("Social Media"). We may post (or re-post) on our Websites and our Social Media pages any comments or content that you post on our Social Media pages. Your use of Social Media is governed by the privacy policies and terms of the third parties that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.

SECURITY

We employ technical, administrative, and physical measures to protect Personal Information from unauthorized access, loss, or misuse, appropriate to the sensitivity of the data. These safeguards may include encryption in transit and at rest, network firewalls, and access controls. With respect to Student Personal Information, we adhere to the security requirements in our School agreements, including requirements for encryption, access restrictions, and confidentiality protocols where applicable. For more information about our security program, please review our Security Overview, available at Security Overview.

We also maintain an internal Incident Response Plan and Breach Notification Procedure. In the event of a data breach affecting Personal Information, we will respond according to this plan and promptly provide any required notifications to affected Schools and individuals in compliance with applicable law and our contractual obligations. An overview of our Incident Response Plan and Breach Notification Procedure is available at Incident Response Plan. Where a security incident involves Student Personal Information, we will notify the affected School without undue delay and, unless a shorter period is required by law or our agreement, no later than seventy-two (72) hours after we confirm the incident. We will cooperate with the School in investigating and remediating the incident and in meeting its own notification obligations to students, parents, guardians, and regulators.

While we strive to safeguard Personal Information, no security system is foolproof, so we cannot guarantee absolute security. We encourage you to protect your login credentials and promptly inform us of any suspected unauthorized activity.

INTERNATIONAL USERS

Our Services are intended for use within the United States of America, and our primary operations are based in the United States of America. If you access our Services or Websites from outside the United States of America, please be aware that any Personal Information you provide may be transferred to, stored in, and processed in the United States of America, where our servers and operations are located. Data protection laws in the United States of America may differ from those in your country of residence. By using our services and submitting your information, you acknowledge and consent to this transfer and processing in accordance with this Policy.

CHANGES TO THIS POLICY

We may update this Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other operational needs. When we make material changes, we will notify users by posting an updated version on our Websites and, where required by law or otherwise appropriate, by providing additional notice such as via email or through the Services. All updates will be identified by the "Effective Date" or "Last Updated" date at the top of this Policy.

Unless otherwise stated in the notice, changes will take effect when the updated version of this Policy is posted. Your continued access, use or interaction with our Services or Websites after the updated version of this Policy becomes effective will constitute your acknowledgment of the changes and your agreement to the updated collection, use and disclosure practices described in the updated version of this Policy.

CONTACT US

If you have any questions about our privacy practices or this Policy, please contact us at:

Game-U, LLC
203 Main Street, Suite 300
Flemington, NJ 08822
support@game-u.com