Privacy Policy
Last modified: August 11, 2022
Who We Are
Ripple Studios Inc. (“we”, “our”, “us”, the “Company”) is on a mission to inspire students to pursue careers in Science, Technology, Engineering, and Math (STEM). In the pursuit of this mission, we commit to the protection of users’ privacy in order to provide a safe environment for users to engage with our services. We provide websites, including ripplestudiosinc.com and its subdomains (collectively, the “Websites”), video games (collectively, the “Games” and each the “Game”), and other online services (collectively, the “Services”). This Privacy Policy (this “Policy”) outlines the user data that we collect, why we collect it, how it is used, and the rights that a user has to their own data. By using our Services, you are confirming that you understand this Policy. Should you have questions about this Policy, please contact us by emailing us at [email protected], so that we can clarify and address your questions.
Legal Framework
The Company is domiciled in Canada. Therefore, it is governed by the laws and regulations of Canada.
COPPA Compliance
The Company creates Services that are directed at users under the age of 13. In order to protect the privacy of children, the Company ensures that its privacy policy is in compliance with the Children’s Online Privacy Protection Act. The full Act can be read at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule. The Company abides by the following procedures to ensure the protection of the privacy of children when using the Services:
- A user is considered a “child” if they are under the age of 13
- Requires all users to specify their Date of Birth prior to the collection of any personal information the first time that they use a Service or the first time they use the Service after any change to the Privacy Policy
- If a user is under the age of 13, explicit and verifiable parental consent is required to allow the user to continue to access any Service. When providing consent, a parent must review the Privacy Policy to understand the collection, use, and/or disclosure of personal information from the child by the Service.
Data Collection
The Personal Information we collect from or about users is used to provide access to certain features of the Game and to communicate with the same user. We do not share or otherwise disclose Personal Information, except (1) as may be necessary to protect the safety of a user, including by disclosing their Personal Information, where appropriate, to law enforcement agencies or for an investigation related to public safety;
(2) to enable us to take precautions against liability; (3) to protect the safety and security of the Game; or (4) where required to do so by law or legal process.
We may collect different types of information from you depending on how you use our Services, including Personally Identifiable Information. Personally Identifiable Information (PII or “Personal Information”) is any information you provide to us that personally identifies you, like your name or email address, or other information which could be reasonably linked to such identifying information by us. We will only collect, use, and share your personal information in accordance with this Privacy Policy. The categories of Personal Information we may collect are listed below. Certain types of Personal Information may fall under more than one category.
| Category | Personal Information | Purpose |
|---|---|---|
| Identifiers | First and last name |
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| Postal address |
| |
| Username or screen name |
| |
| Unique or online ID (such as an account ID, support ticket ID, or third party ID) |
| |
| Internet Protocol address |
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| Device identifiers and device information |
| |
| Advertising ID |
| |
| Email address |
| |
| Protected classification characteristics under California or federal law | Date of birth |
|
| Commercial information | Payment information |
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| Purchase history |
| |
| Internet or other similar network activity | Interaction with the Websites |
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| Gameplay information |
| |
| Geolocation data | Geolocation |
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| Postal Code / Zip Code |
| |
| City |
| |
| Province, State, or Country |
| |
| Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | First and last name |
|
| Postal address |
| |
| Telephone number |
| |
| Payment information |
| |
| Other | Information from the content that you share publicly in the Game through public functions |
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| Information from the content that you send to us directly when you contact us or report a problem with the Services (including if you report a problem with another user) |
| |
| Gaming-related linked accounts |
| |
| The parent or legal guardian of a Child who is over 18 years old |
|
We may also collect information that does not generally identify you but may become associated with your account. We may use information that does not identify you for any permissible business purpose under applicable law.
Data Use
In addition to the purposes described above, we may collect your Personal Information for the below purposes:
- To provide or improve the Services: We may use your Personal Information to process your requests to access the Services and certain of their features and to generally present and improve the Services. For example, we may use your Personal Information to improve the Game.
- To administer the Services: We may use your Personal Information for any lawful business purpose in connection with administering the Services. For example, if you contact us by email, we may use your Personal Information to respond to you or to troubleshoot a problem you reported having with the Services.
- To market the Services: We may use your Personal Information to market the Services to you. For example, with your prior consent, we may send you news and updates about our products and the Services.
- In furtherance of legal, health, and safety objectives: We may access, use, and share with others your Personal Information for purposes of health, safety, and other matters in the public interest. We may also provide access to your Personal Information to cooperate with official investigations or legal proceedings (e.g., in response to subpoenas, search warrants, court orders, or other legal processes). We may also provide access to your Personal Information to protect our rights
and property and those of our agents, users, and others including to enforce our agreements, policies, and our Terms of Use. - In connection with a sale or other transfer of our business: In the event all or some of our assets are sold, assigned, or transferred to or acquired by another company due to a sale, merger, divestiture, restructuring, reorganization, dissolution, financing, bankruptcy, or otherwise, your Personal Information may be among the transferred assets.
- As we may describe to you when collecting your Personal Information: There may be other situations when we collect your Personal Information and simultaneously describe the purpose for that collection.
Data Sources
We may collect your Personal Information when you provide it to us directly. For example:
- When you create an account for the Game, we may collect your username, email address, and Internet Protocol address.
- When you use the public functions in the Game, we may collect the information you choose to disclose.
- When you voluntarily provide it to us with your specific, informed, and unambiguous consent (for example, when you sign up for our newsletter).
- When you contact us or report a problem with the Services, we may collect your email address, records, and copies of your correspondence.
- When you respond to a survey or questionnaire, we may collect the information provided.
We may collect your Personal Information automatically as you use our Services. For example, we may collect your Personal Information as you interact with our Websites or as you play the Game.
User Information Visible to Other Users
The Game does not have any user-to-user interactive content and as such, no individual user can access Personally Identifiable Information of another user. For the purposes of Game leaderboards, public contests, public announcements, or similarly public Services, the only information that will be published about a specific user account will be the username. For example, if there was a public contest with a leaderboard of high scoring accounts published on the Website, a list of the high scoring usernames will be published.
Data Sharing
We do not share personal information with any third parties except in the limited circumstances described in this Privacy Policy:
- We work with vendors, service providers, and other partners to help us provide the Service by performing tasks on our behalf. We may need to share or provide information (including personal information) to them to help them perform these business functions, for example sending emails on our behalf, database management services, database hosting, targeted advertising (for users 13 years of age and older), providing customer support software, and security. Generally, these service providers do not have the right to use users’ personal information we share with them beyond what is necessary to assist us. Additionally, these service providers must adhere to confidentiality and security
obligations in a way that is consistent with this Privacy Policy. - We post testimonials on our Service which may contain personal information such as the name, photo, and/or a video of the individual in the testimonial. We obtain the individual’s consent in advance to ensure we have permission to post this content publicly. To request removal of a student’s personal information from our testimonials, please contact us at [email protected]
- We use analytics services, including mobile analytics software, to help us understand and improve how the Service is being used. These services may collect, store, and use information in order to help us understand things like how often students use the Service, the events that occur within the application, usage, performance data, and from where the application was downloaded.
- We may share aggregated, non-personally identifiable information publicly, including with users, partners, or the press in order to, for example, demonstrate how the Service is used, spot industry trends, or to provide marketing materials for the Company. Any aggregated information shared this way will not contain any personal information.
- We may disclose personal information if we have a good faith belief that doing so is necessary to comply with the law, such as complying with a subpoena or other legal process. We may need to disclose personal information where, in good faith, we think it is necessary to protect the rights, property, or safety of the Company, our employees, our community, or others, or to prevent violations of our Terms of Service or other agreements. This includes, without limitation, exchanging information with other companies and organizations for fraud
protection or responding to government requests. - Over time, the Company may grow and reorganize. We may share users’ personal information with affiliates such as a parent company, subsidiaries, joint venture partners, or other companies that we control or that are under common control with us, in which case we will require those companies to agree to use students’ personal information in a way that is consistent with this Privacy Policy.
Data Collected by Third Parties
The Company uses various vendors, partners, and service providers to help us deliver our services to our users. For example, we use a mail service called MailChimp to deliver emails to our users on our behalf. As a result, some of your information, including Personally Identifiable Information, may be shared with our service providers in order for
them to perform their tasks. Wherever possible, we ensure that we only share the minimal amount of information for the respective service provider to perform their service. We review all of our service providers and ensure that they protect and secure your information in a way that is consistent with this Privacy Policy. We use third-party analytics services to better understand how our users are interacting with our Services
and to improve our Services over time. For example, we use Unity Analytics to analyze your use of the Game. In this process, some of your personal information, Performance Data, and interactions with our product may be collected by or shared with these analytics services in order for them to perform their service. We carefully vet all of our analytics services and ensure that they protect and secure your information in a way that
is consistent with this Privacy Policy. You can view the Privacy Policies of our Third Party service providers from their respective websites:
- Unity Analytics: Unity Technologies, 30 3rd Street, San Francisco, CA 94103. Unity Analytics collects Personal Information directly from your device and uses this Personal Information to help us analyze your use of the Game. You can view their Privacy Policy, which includes instructions on how to restrict the collection of Personal Information: https://unity3d.com/legal/privacy-policy
- Mailchimp: The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA. Mailchimp is an emailing service that collects Personal Information connected to your email address. You can view their Privacy Policy, which includes instructions on how to restrict the connection of Personal Information: https://mailchimp.com/legal/privacy/
Right to Access, Rectification, Erasure, Portability, and Lodge a Complaint
Subject to any limitations and exceptions under applicable law, you have the right to request access to your Personal Information and exercise the following rights:
- You have the right to correct or update certain types of Personal Information. In many cases, you can review or update your account information by accessing your account online.
- You have the right to request deletion of your Personal Information. If you choose to have your Personal Information removed from the Services, we will carry out your request within 30 days of account verification, subject to extension, and we will only retain minimal Personal Information to document your request and the actions we took to carry out your request.
- You have the right to restrict certain processing of your Personal Information and the right to object to some types of processing of your Personal Information.
- You have the right to withdraw your consent at any time, including objecting to your Personal Information being used for marketing or advertising purposes.
We will comply with your requests in accordance with, and subject to, applicable law. For example, we are not required to delete your Personal Information if we have an overriding legitimate ground for retaining that information, such as to prevent fraud.
Please note that we are legally prohibited from carrying out requested actions in some instances, including (1) when we are unable to confirm your identity and (2) where doing so would adversely affect the rights or freedoms of other individuals. Further, we are not required to carry out a requested action in some instances, including where the request is considered excessive.
You have the right to lodge a complaint regarding our collection, storage, or processing of your Personal Information with a data protection supervisory authority in the country where you live or work.
Parental Rights
If you are the parent or legal guardian of a child who has used any Service and you were not informed by your child’s teacher or school (as per COPPA), you can email us at [email protected] to have that child’s account deleted. Any parents that want copies of their children’s personal information that we may have stored can contact us by sending an email to [email protected] At any time, parents can refuse to permit us to collect further personal information from their children and can request that we delete the personal information we have collected from their child by contacting us at [email protected] Please keep in mind that deleting records may require us to terminate the account in question. Also remember that before we can share the information with you, or delete it per your request, we will need to verify your identity, for example by requiring that you provide acceptable forms of personal identification.
Data Retention
We protect your Personal Information through a combination of collection, security, and retention policies.
- Limited retention: We only keep your Personal Information for as long as we need it for business and operational needs or to comply with any statutory, regulatory, or legal obligations. For example, we may retain Personal Information collected from you to support user inquiries and prevent repeated violations or suspected violations of our Terms of Use if your account has been banned or your access to the Services has been disabled for any reason.
- Purpose limitation: We will use your Personal Information only for the Services you choose to access and for the purposes for which you choose to share it. We will respect your requests to start or stop processing your Personal Information for marketing purposes, as well as the types of marketing messages you may wish to receive.
- Security measures: We use appropriate measures to ensure a level of security appropriate to the risk involved and have implemented contractual, technical, administrative, and physical security measures designed to protect Personal Information from unauthorized access, disclosure, use, and modification. As part of our privacy compliance processes, we review these security procedures on an ongoing basis to consider new technology and methods as necessary. However, please understand that our implementation of security measures as described in
this Policy does not guarantee the security of your Personal Information. In the event of a security breach, we will notify the proper regulatory authorities and any affected users of the breach within 72 hours after we become aware of the breach.
Modifications to Privacy Policy
The Company reserves the right to periodically review and change this Policy from time to time and we will notify users who have enabled the notification preference about changes to our Privacy Policy. Continued use of the Service will be deemed as acceptance of such changes.