We want to explain what Personal Information we process for this game.

• You cannot play the game without a guest account or a full account.

• Any type of account creates and stores an account ID that is used for moderation and account linking.

• If you create a guest account, your username, IP address, and gameplay information will be stored so you can play the game. However, this information is not stored after the game ends unless you are reported by another player.

• If you create a full account, we will store your username and sign-in IDs and track gameplay information across platforms.

• To protect children, we will use your date of birth, country, and IP address to verify whether you are a child or not. This information is not stored.

• If you reach out to us directly, we may use that information to help fix the problem.

• Please do not put private information in your username or chat. Someone may save or use that information even if we do not.

Green Country Technology Center School District No. 28 (“GCTC”) provides various games created by its students as part of its educational programming.

1. What does this Privacy Policy cover?

   This Privacy Policy (this “Policy”) sets forth how GCTC collects, uses, protects, stores, discloses, and otherwise processes your Personal Information (defined below).

   This Policy also does NOT apply to information you provide to any third party or is collected by any third party (except as otherwise provided below).

   By using our Services, you are confirming that you understand English well enough to understand this Policy. If you have questions about this Policy, please contact us by emailing us at appstores@gctcok.edu, so we can clarify and address your questions.

2. What categories of Personal Information do we collect?

   We may collect different types of information from you depending on how you use our Services, including Personal Information. “Personal Information” is information that relates to an identified or identifiable natural person. The categories of Personal Information we may collect are listed below. Certain types of Personal Information may fall under more than one category.

   The Games are not intended for children under the age of 13, and we do not knowingly collect any Personal Information from children under the age of 13. Additional age-based privacy information

   specific to California residents is set forth below. If you believe we have inadvertently collected information about your child, please contact us at appstores@gctcok.edu so we can promptly remove the information.

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.

3. From what sources do we collect Personal Information?

   Information You Provide:

   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 contact us or report a problem with the Services, we may collect your email address and records and copies of your correspondence.

   • When you respond to a survey or questionnaire, we may collect the information provided. Information Collected Automatically:

     We may collect your Personal Information automatically as you use our Services. For example, we may collect your Personal Information as you play the Game. For more information about our and third parties’ use of cookies and other automatic data collection technologies and certain choices we offer you with respect to them, please see Section 4 below.

     Information From Third Parties:

     We may receive your Personal Information from or through third parties that help us provide or facilitate your access to the Services. For example, we may receive your Personal Information from:

   • Other users of the Game: If a user reports to us that you are attempting to hack the Game, for example, we may collect the information provided by that user about you and create a report of your actions.

     We abide by this Policy when we use Personal Information provided to us by third parties. However, we may not control the Personal Information that third parties collect or how they use that Personal Information. You should review the third parties’ privacy policies for more information about how they collect, use, and share the Personal Information they obtain and use.

4. How do we and third parties use cookies and other automatic data collection technologies?

   Cookies are small data file identifiers that are transferred to your computer or mobile web browser that allow us and third parties to recognize your browser or mobile device and transfer information about you and your use of our Services.

   We may use cookies and other automatic data collection technologies on the Services to collect Personal Information, for example, when you play the Game, we may automatically collect your username, Internet Protocol address, and gameplay information, such as events completed or actions taken within the Game.

   Cookies and other automatic data collection technologies in the Games may come from third parties. These cookies and other automatic data collection technologies improve your experience by helping us better tailor our Services to you.

   You may set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. Please note that, if you disable or refuse cookies or other automatic data collection technologies, some aspects of the Games may be inaccessible or not function properly.

   The Games may employ ad serving technologies that use cookies, clear GIFs, web beacons, tracking pixels, and other similar technologies like identifiers to deliver offers to you. Some of these technologies can sync or connect behavior across different mobile apps, devices, and websites. The ads can be tailored to your interests.

   These technologies collect and use information so we can serve appropriate advertising to you and help track results and measure effectiveness. In addition to device advertising identifiers, this information includes

   Third party advertising companies may combine the information collected in the context of delivering an ad to you via our products with other information they have independently collected over time and across different products, websites, and services. Many of these companies collect and use information under their own privacy policies.

   California only. Prior to being shown ads in the Games, you will be asked to verify whether you are over the age of 16. If you are not, you will be asked whether you consent to the tracking that enables personalized ads. You have the right to change your consent status at any point in time. If you have questions about how to change your consent status or to inquire regarding your rights to reassure or data portability, please contact us at appstores@gctcok.edu.

   • Advertisements served and the location of the ad;

   • Length of time an advertisement was visible;

   • Domain type, IP address, size of the advertisement; and advertisement response.

5. For what purposes do we collect your Personal Information?

   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 Games.

   • 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 reach out to us, we may use your Personal Information to respond to you or to troubleshoot a problem you reported having with 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 and policies.

   • 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.

     We only collect, use, or store your Personal Information for a lawful basis such as:

   • It is necessary to provide you with a Service that you have requested (for example, providing you access to the Game);

   • We have a legitimate business interest that is not outweighed by your privacy rights (for example to provide player support); or

   • It is necessary to protect your vital interests or the vital interests of others (for example, we may collect or share Personal Information where necessary to resolve an urgent medical situation or protect the health or safety of one of our users or someone else).

6. In what situations do we disclose your Personal Information?

   We may disclose your Personal Information to a third party, such as a service provider for a business purpose. When we disclose Personal Information for a business purpose, we enter into a contract with the service provider that describes the purpose and requires the service provider to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

   We may also disclose your Personal Information:

   • To our lawyers, consultants, accountants, business advisors, and similar third parties who owe us duties of confidentiality;

   • To comply with any court order, law, or legal process, such as responding to a government or regulatory request;

   • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our users, or others; and

   • If you have consented to such a disclosure.

7. How is my Personal Information protected?

   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.

   • 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 promptly notify the proper regulatory authorities and any affected users of the breach after we become aware of the breach.

     Your practices and activities are likewise very important for the protection of your own Personal Information. You can take certain steps to help protect your Personal Information, such as being mindful of what you share publicly in the Game. For example:

   • Do not use your real name when selecting a username.

   • Do not post your real name in public-facing areas of the Services and do not share anything private about yourself or anyone else.

   • Do not pick a password that is easy to guess and do not share your password.

     Please remember that we have no control over what third parties do with the content of your communications and no responsibility or obligation regarding third parties.

8. What rights do you have to your Personal Information?

   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.

   • You have the right to request deletion of your Personal Information. If you chose to have your Personal Information removed, 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. 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.

     Please email us at appstores@gctcok.edu with the subject line “Privacy Request” if you would like to exercise any of the rights described above or if you have questions regarding your rights.

     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.

9. Additional Notice for California Residents

   Do Not Track Signals

   The following applies to California residents pursuant to the California Online Privacy Protection Act:

   We do not track users of our Services over time and across third party websites or online services and therefore do not respond to Do Not Track signals. We are not aware of any third party that tracks users of our Services over time and across third party websites or online services.

   California Shine the Light Law

   The following applies to California residents pursuant to the California Shine the Light Law:

   California residents may request information from us concerning any disclosures of Personal Information we may have made in the prior calendar year to third parties for direct marketing purposes. If you are a California resident and you wish to request information about our compliance with this law or our privacy practices, please contact us at appstores@gctcok.edu.

   California Consumer Privacy Act of 2018

   The following applies to California residents pursuant to the California Consumer Privacy Act of 2018 (“CCPA”):

   In the preceding 12 months, we disclosed the categories of Personal Information listed in Section 2 above for business purposes to those service providers identified in Section 6 above.

   In the preceding 12 months, we may have sold the following categories of Personal Information to our advertising partners, Unity Ads: country, device information, Internet Protocol address, device and online identifiers, and information regarding gameplay and purchases made in the Game. We only disclose Personal Information to our service providers identified in Section 6 above.

   You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you, to the extent retained by us:

   We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm that the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request.

   Response Timing and Format under CCPA

   We endeavor to respond to a verifiable consumer request under CCPA within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

   Any disclosures we provide will only cover the 12-month period preceding the receipt of verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

   For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

   We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

   • The categories of Personal Information we collected about you.

   • The categories of sources for the Personal Information we collected about you.

   • Our business or commercial purpose for collecting or selling that Personal Information.

   • The categories of third parties with whom we share that Personal Information.

   • The specific pieces of Personal Information we collected about you (also known as a data portability request).

     If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: (1) sales, identifying the Personal Information categories that each category of recipient purchased, and (2) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

     You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your

     Personal Information from our records, unless an exception under CCPA applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

   • Complete the transaction for which we collected the Personal Information, provide the Service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

   • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

   • Debug the Services to identify and repair errors that impair existing intended functionality.

   • Exercise free speech, ensure the right of another user to exercise their free speech rights, or exercise another right provided for by law.

   • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. Seq.)

   • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

   • Enable solely internal uses that are reasonably aligned with user expectations based on your relationship with us.

   • Comply with a legal obligation.

   • Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

     We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

   • Deny you the Services.

   • Charge you different prices or rates for the Services, including through granting discounts or other benefits, or imposing penalties.

   • Provide you a different level or quality of the Services.

   • Suggest that you may receive a different price or rate for the Services or a different level or quality of the Services.

     Verifiable Consumer Requests under CCPA

     To exercise your rights described above, please email us at appstores@gctcok.edu with the subject line “CCPA” or mail your request to 1100 OK-56 Loop, Okmulgee, OK 7447. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

   • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

   • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

10. How will we notify you of changes to this Policy?

    We reserve the right to change this Policy from time to time consistent with applicable law. If we make changes to the Policy, we will notify you by revising the date at the top of this Policy and, in some cases, we may provide you with additional notice (such as adding a statement in the Game or the homepages of our Services, or sending you an email notification).

    In the event that any changes we make to this Policy affect children in a way that requires prior parental consent under COPPA, we will obtain such prior parental consent.

11. How can you contact us? If you have questions, you may email us at appstores@gctcok.edu. If you are a law enforcement agency, please email us at appstores@gctcok.edu with your request for Personal Information with the subject line “Law Enforcement Request.”