CHILDREN'S PRIVACY & STUDENT DATA PROTECTION NOTICE

Last Updated: 2026-07-15

Game-U, LLC ("Game-U," "we," "us," or "our") is committed to protecting the privacy of children and students who use 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"). This notice supplements our Privacy Policy and provides additional information about how we collect, use, disclose, retain, and protect Personal Information from children and students in connection with our Individual Services and School Services. This notice is intended to help describe our practices under the Children's Online Privacy Protection Act ("COPPA"), the Family Educational Rights and Privacy Act ("FERPA"), and applicable student privacy laws.

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"). In this notice, Personal Information collected, received, or used in connection with the Individual Services is referred to as "Individual Personal Information," and Personal Information collected, received, or used in connection with the School Services is referred to as "Student Personal Information."

Summary of Key Commitments and Rights

Separate Treatment for Individual Services and School Services: We tailor our privacy practices based on whether the Services are provided directly to individuals or through a School. Student Personal Information collected through School Services is used only for authorized educational purposes and related legal, safety, and operational needs. Children's Individual Personal Information is handled in accordance with COPPA and is not used for marketing or promotional communications to children.

Parental Rights: Parents and guardians may have the right to access, review, update, and delete their child's Personal Information. For Individual Services, parents and guardians may also withdraw consent for further collection or use, subject to applicable legal and permitted retention requirements.

School Control and FERPA: For students using Game-U through a School, Student Personal Information is controlled by the School. Game-U acts as a "school official" under FERPA, using Student Personal Information only for the School's authorized educational purposes and under the School's direction.

Security and Data Protection: We use technical, administrative, and physical safeguards appropriate to the sensitivity of the Personal Information we handle. These safeguards may include encryption in transit and at rest, network firewalls, access controls, confidentiality requirements, and other protective measures.

Transparency and Breach Notification: We strive to be transparent about our Personal Information practices. If a data breach affecting Personal Information occurs, Game-U will provide required notifications to affected Schools and individuals in compliance with applicable law and our contractual obligations.

More details are provided below. We have separated the information for Individual Services and School Services because consent, access, correction, deletion, and School oversight are handled differently in each context.

Children Using Game-U Through Individual Services

If a student under 18 uses Game-U through the Individual Services, we provide notice to, and obtain verifiable parental consent from, the student's parent or guardian before collecting or using that student's Individual Personal Information, as required by applicable law.

• Notice and Parental Consent: Before collecting or using Individual Personal Information from a student under 18 in connection with the Individual Services, we provide notice of our privacy practices to, and obtain verifiable parental consent from, that student's parent or guardian. If we receive Individual Personal Information from a student under 18 before obtaining verifiable parental consent, such as when a student attempts to sign up on their own, we use that information only to provide notice of our privacy practices and attempt to obtain verifiable parental consent.
• Personal Information We Collect in the Individual Services: Depending on how the Individual Services are used, we may collect categories of Individual Personal Information described in the Privacy Policy, including identifiers and contact information, demographic information, internet and network activity information, coursework information, skills information, commercial information, communication content, and audio and video recordings.
• How We Use Individual Personal Information: We use Individual Personal Information to provide and fulfill the Individual Services, communicate with users or their parents and guardians, provide customer support, operate and secure the Services, improve the Services and conduct analytics, maintain records, process payments, prevent fraud or unauthorized activity, comply with law, and support business planning. We do not send marketing or promotional communications to children, and children's Individual Personal Information is not used for marketing purposes.
• How We Disclose Individual Personal Information: We may disclose Individual Personal Information with service providers who work for us, with parents or guardians for child users, with a user's consent or at the user's request, for legal, compliance, or safety purposes, and during a business transfer or similar transaction. We never disclose children's Individual Personal Information for advertising purposes.
• Parental Choices and Control: Parents and guardians of children using the Individual Services may contact us to review, correct, or delete their child's Individual Personal Information, or to withdraw consent for further collection or use, subject to any legal, regulatory, tax, accounting, reporting, safety, security, or other permitted retention requirements.

No activity from a child in the Individual Services is conditioned on disclosing more Personal Information than is reasonably necessary to participate in the applicable activity. If parental consent is not provided or is withdrawn, the child may not be able to use some or all of the Individual Services.

Children Using Game-U Through School Services

When Game-U provides School Services, we act as a "school official" under FERPA and provide the Services on behalf of, and at the direction of, the applicable School. The School acts on behalf of the student's parent or guardian to provide any required consent for the student's use of the School Services.

• School Consent under COPPA and FERPA: For 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 use it only for authorized educational purposes of providing and supporting the School's educational program, including improving the educational Services, and for related legal or safety needs.
• Personal Information We Collect in the School Services: Depending on the School's use of the School Services and the School's instructions, we may collect categories of Student Personal Information described in the Privacy Policy, including identifiers and contact information, demographic information where required, internet and network activity information limited to technical data necessary to operate and provide the School Services, coursework information, skills information, educational information, communication content, and audio and video recordings. 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.
• How We Use Student Personal Information: We use Student Personal Information to provide and support the School Services, operate, maintain, and secure the School Services, communicate about educational matters, improve the Services and inform educational strategies, provide customer support and service quality, and ensure legal and policy compliance.
• No Commercial Use of Student Personal Information: Game-U does 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.
• How We Disclose Student Personal Information: We do not disclose Student Personal Information except in limited ways described in the Privacy Policy, including to the student's School and teachers, as directed by the School, to service providers who operate on our behalf, for legal and safety reasons, and in connection with a business transfer or similar transaction.
• Parental Rights and Controls: For School Services, parents and guardians should direct access, correction, deletion, and similar requests to the applicable School. We will help the School provide access, make corrections, or respond to deletion requests to the extent required or permitted by applicable law, our agreement with the School, and the School's instructions.
• Role of Schools and Teachers: The School's authorized personnel can access Student Personal Information through the School Services to support instruction and track progress. Their use of Student Personal Information is governed by the School's policies. Game-U is not responsible for, and does not control, how a School uses or discloses Student Personal Information.

Data Security and Protection

Game-U employs technical, administrative, and physical measures to protect Personal Information from unauthorized access, loss, or misuse, appropriate to the sensitivity of the Personal Information. These safeguards may include encryption in transit and at rest, network firewalls, access controls, confidentiality protocols, and other protective measures.

With respect to Student Personal Information, we adhere to the security requirements in our agreements with Schools, including requirements for encryption, access restrictions, and confidentiality protocols where applicable. 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 that plan and provide required notifications to affected Schools and individuals in compliance with applicable law and our contractual obligations.

Data Retention and Deletion

Game-U retains Personal Information only for as long as necessary to fulfill the purposes described in the Privacy Policy or as required by law.

• Student Personal Information: We retain Student Personal Information only for as long as it serves educational purposes or as required by law or our agreements with the applicable School. We 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 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.
• Individual Personal Information: We retain Individual Personal Information only as long as we have a legitimate business purpose to keep it, such as to provide the Individual Services, ensure the security and integrity of the Services, satisfy legal, regulatory, tax, accounting, or reporting requirements, or otherwise comply with applicable law.

Your Rights and How to Exercise Them

Access and Correction: Users, parents, and guardians may have legal rights, including under COPPA and FERPA, to access, correct, export, or delete certain Personal Information or content, or to make certain choices. For Individual Services, please contact us directly. For School Services, please contact the applicable School, and we will help the School provide access or make appropriate corrections to the extent required or permitted by applicable law or agreement.

Deletion and Consent Withdrawal: For Individual Services, a parent or guardian may contact us to withdraw consent or request deletion of their child's Individual Personal Information, subject to applicable legal and permitted retention requirements. For School Services, deletion requests should be directed to the applicable School, and we will assist the School in responding to those requests in accordance with the School's instructions, our agreement with the School, and applicable law.

School Services Requests: If we receive a request directly from a parent, guardian, or student regarding Student Personal Information collected through School Services, we will refer the request to the applicable School to the extent required or permitted by applicable law or our agreement with the School.

Complaints or Concerns: If you have a concern or complaint about how your child's Personal Information is handled by Game-U:

• Contact Game-U: You may contact us at support@game-u.com. We will work with you and, where applicable, the student's School, to address the concern.
• External Recourse: If you are not satisfied with our response, you may have the right to contact the applicable education privacy authority or other regulator with jurisdiction over the matter. For example, New York parents, eligible students, or other authorized individuals may be able to file a complaint with the New York State Education Department's Chief Privacy Officer regarding an alleged unauthorized release or disclosure of Student Personal Information. You may also contact us so we can try to address the concern directly.

Contact Information

If you have any questions about this Children's Privacy & Student Data Protection Notice or about how Game-U handles Individual Personal Information or Student Personal Information, please contact us at:

• Email: support@game-u.com
• Mailing Address: Game-U, LLC
• 203 Main Street, Suite 300
• Flemington, NJ 08822

This notice supplements the Game-U Privacy Policy and provides additional information for parents, guardians, and Schools about Game-U's practices for Individual Personal Information and Student Personal Information.