Privacy Policy

enAbleGames

Privacy Policy

Last modified: January 1, 2018

1. Introduction

enAbleGames, LLC (“Company” or  “We”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit our Sites www.enablegames.com, or use our software products and any related mobile applications and/or games (collectively, the  “Sites”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On the Sites.
• In email, text, and other electronic messages between you and the Sites.
• Through mobile and desktop applications you download from the Sites, which provide dedicated non-browser-based interaction between you and the Sites.

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
• any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Sites.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Sites. By accessing or using the Sites, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Sites after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

1. Children Under the Age of 13

The Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”) require us to inform parents and legal guardians (as used in this section, “parents”) about our practices for collecting, using, and disclosing personal information from children under the age of 13 (“children”). It also requires us to obtain verifiable consent from a child’s parent for certain collection, use, and disclosure of the child’s personal information.

This section notifies parents of:

• The types of information we may collect from children.
• How we use the information we collect.
• Our practices for disclosing that information.
• Our practices for notifying and obtaining parents’ consent when we collect personal information from children, including how a parent may revoke consent.

This section only applies to children under the age of 13 and supplements the other provisions of this privacy policy.

Information We Collect from Children

Children can access limited parts of our public-facing Sites without providing us with any personal information. However, some content and features, including games, interactive features, and the ability to communicate with other users are available only to registered users and/or require us to collect certain information, including personal information, from them. We require parents to register user accounts on behalf of their children, which are verified with credit card information, prior to allowing children to use portions of the Sites which collect personal information.  In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they visit or use the Sites.

We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary.

Information We Collect Directly. As part of parents’ account registration we require a username and a parent’s valid email address. In the event a parent creates an account specifically for their child’s use we may require the child’s name.  We also require each user to maintain a member name and password. We may request additional information directly from your child, but this information is optional. We specify whether information is required or optional when we request it. In the event we learn that we have collected personal information from a child without parental consent we will take steps to delete such information as soon as possible.  Parents who believe that their child has submitted personal information to us without their consent may contact us at support@enablegames.com

We may enable registered users to communicate with others, including clinicians, therapists or other providers designated by you, on or through the Sites through chat, email, or posting to public areas of the Sites (“Social Features”). The nature of these features allows children to disclose personal information about themselves. We do not monitor or review this content before it is posted, and we do not control the actions of third parties with whom your child shares his or her information. We encourage parents to educate their children about safe Internet use and to monitor their children’s use of social features.

Automatic Information Collection and Tracking. We use technology to automatically collect information from our users, including children, when they access and navigate through the Sites and use certain features. The information we collect through these technologies may include one or more persistent identifiers that can be used to recognize a user over time.

We also may combine non-personal information we collect through these technologies with personal information about you or your child that we collect online.

For information about our automatic information collection practices, including how you can opt out of certain information collection, see Sections III  and IV of this Privacy Policy.

How We Use Your Child’s Information

We use the personal information we collect from your child to:

• register them with the Sites;
• communicate with them about activities or features of the Sites that may be of interest;
• track their performance in games or other activities;
• communicate with the clinicians, therapists or other providers designated by you about your child’s performance and use of the Sites.

We use the information we collect automatically through technology (see Automatic Information Collection and Tracking) and other non-personal information we collect to improve our Sites and to deliver a better and more personalized experience by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about the child’s preferences, allowing us to customize the content according to individual interests.
• Speed up your searches.

Our Practices for Disclosing Children’s Information

We do not share, sell, rent, or transfer children’s personal information other than as described in this section.

We may disclose aggregated information about many of our users, and information that does not identify any individual. In addition, we may disclose children’s personal information:

• To third parties we use to support the internal operations of our Sites and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.
• If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of enAbleGames, LLC, our customers or others, including to:
• protect the safety of a child;
• protect the safety and security of the Sites; or
• enable us to take precautions against liability.
• To law enforcement agencies or for an investigation related to public safety.

In addition, if the Company is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the personal information we have collected or maintain to the buyer or other successor.

Accessing and Correcting Your Child’s Personal Information

At any time, you may review the child’s personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child’s information.

You can review, change, or delete your child’s personal information by:

• Logging into your child’s account and visiting his or her account profile page.
• Sending us an email at support@enablegames.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.

• Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Sites, including information:

• by which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”);
• that is about you but individually does not identify you, such as information about your specific use of the Sites and performance with respect to any games contained therein; and/or
• about your Internet connection, the equipment you use to access our Sites and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the Sites. Information collected automatically may include usage details, IP addresses, and information collected through cookies, and other tracking technologies.

Information You Provide to Us.  The information we collect on or through our Sites may include:

• Information that you provide by filling in forms on our Sites. This includes information provided at the time of registering to use our Sites, posting material, or requesting further services. We may also ask you for information when you report a problem with our Sites.
• Information generated by your use of the Sites, including participation in games, such as information about your physical movements and active time, which will vary based on activity and game.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Sites and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Sites.
• Information about your use of the Sites, including information regarding your game play such as body tracking data, biometric sensor data, and game performance data.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Sites, or transmitted to other users of the Sites or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that we cannot control the actions of other users of the Sites with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies.  As you navigate through and interact with our Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Sites, including traffic data, logs, and other communication data and the resources that you access and use on the Sites.
• Information about your computing device and Internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically does not include personal information but we may associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Sites and to deliver a better and more personalized service.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Sites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Sites.

Web Beacons. Pages of our the Sites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies [and Other Tracking Technologies.

Some content or applications, including advertisements, on the Sites are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Sites. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

1. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Sites and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To communicate about your usage of the Sites with your approved clinicians, therapists or other providers and to allow you to connect and communicate with other users including any clinicians, therapists or other providers designated by you.
• To provide you with notices about your account.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Sites or any products or services we offer or provide though it.
• To allow you to participate in interactive features on our Sites.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

1. Disclosure of Your Information

We may disclose aggregated information about our users without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To the clinicians, therapists or other providers designated by you.
• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Sites users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our End User License Agreement, available at www.enablegames.com/legal, and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

1. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.
• Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to support@enablegames.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Sites and visiting your account profile page.

You can delete your account at any time through the Sites or by contacting us at support@enablegames.com, though it may take time to delete all of your associated account information.

You may also send us an email at support@enablegames.com to request access to, correct or delete any personal information that you have provided to us. In some instances we may not be able to delete your personal information without deleting your user account. We may not accommodate a request to change or delete information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Sites, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Sites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to legal@enablegames.com or write us at: enAble Games, LLC, 3401 Market St., Suite 200, Philadelphia PA 19102, Attn.: Legal Department.

• Data Security

We have implemented commercially reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted by us or our third party payment processor using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Sites. The information you share in public areas may be viewed by other users of the Sites.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Sites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites.

• Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Sites home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Sites and this privacy policy to check for any changes.

1. Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

enAbleGames, LLC

3401 Market St., Suite 200

Philadelphia PA 19102

Email: legal@enablegames.com