Ciphertainment Privacy Policy

Ciphertainment (“Ciphertainment,” “we,” “us,” or “our”) is committed to protecting the privacy and safety of everyone who uses GenX Defenders (“GenX Defenders,” the “Game,” or the “Service”).

GenX Defenders is an educational cybersecurity action-adventure game designed primarily for children and young people between 10 and 16 years of age, while also being suitable for adults who wish to learn about cybersecurity through gameplay.

Because our Game is designed for younger users, we take particular care to minimize the personal information we collect, explain our practices in clear language, and provide appropriate protections for children and their parents or guardians.

This Privacy Policy explains what information we collect, how we use it, when we may disclose it, how we protect it, how long we retain it, and the choices available to players and their parents or guardians.

By using GenX Defenders, you acknowledge the practices described in this Privacy Policy. Where applicable law requires parental or guardian consent, we will obtain that consent before collecting, using, or disclosing a child's personal information.

1. Who This Privacy Policy Applies To

This Privacy Policy applies to:

• children and young people who play GenX Defenders;
• parents and legal guardians of players;
• educators, schools, organizations, or other adults who access GenX Defenders; and
• other individuals who interact with Ciphertainment or the Game.

If a child is using GenX Defenders, references to “you” may also refer to the child's parent or legal guardian where applicable.

2. Our Approach to Children's Privacy

GenX Defenders is designed for users aged 10–16.

We recognize that children and young people require additional privacy protections. Our approach is based on the principles of:

• Data minimization: We collect only information reasonably necessary to operate, secure, support, and improve the Game.
• Purpose limitation: We use information only for the purposes explained in this Privacy Policy.
• No unnecessary profiling: We do not use children's personal information to build profiles for targeted advertising or unrelated commercial purposes.
• No sale of children's personal information: We do not sell children's personal information.
• No targeted advertising to children: We do not use children's personal information to provide targeted or behavioral advertising.
• Limited disclosure: We disclose personal information only when necessary to provide the Game, operate our business, comply with law, protect users, or with appropriate consent.
• Security: We use reasonable administrative, technical, and physical safeguards to protect personal information.

Apple's guidelines impose additional requirements on apps intended for children, including restrictions on third-party advertising, analytics, and transmission of children's personal or device information.

3. Information We May Collect

The information we collect depends on how GenX Defenders is used.

3.1 Information Provided Directly to Us

Depending on the features available, we may collect information such as:

• first name or nickname;
• email address;
• parent or guardian contact information;
• account credentials;
• information provided when contacting customer support;
• information provided when reporting a technical problem;
• information provided by a parent, guardian, educator, school, or organization; and
• information necessary to process a purchase, where applicable.

We do not require children to provide their real name, home address, telephone number, precise location, photographs, or other unnecessary identifying information simply to play the Game.

Where possible, we encourage players to use a nickname or game-generated identifier instead of their real name.

3.2 Game and Gameplay Information

When a player uses GenX Defenders, we may collect information necessary to operate the Game, such as:

• game progress;
• missions completed;
• achievements;
• scores;
• levels or stages reached;
• game settings;
• saved-game information; and
• other information necessary to provide gameplay functionality.

Where gameplay information can be associated with a player account, we treat that information as personal information where applicable law requires.

3.3 Device and Technical Information

We may automatically receive limited technical information necessary to operate, maintain, secure, and troubleshoot the Game, such as:

• device type;
• operating system and version;
• application version;
• language or regional settings;
• approximate technical information about the device;
• crash reports;
• error information;
• diagnostic information; and
• information concerning the performance and functionality of the Game.

We seek to minimize the collection of device information from children and do not collect precise location information unless a future feature requires it and appropriate notice and consent have been provided.

3.4 Information from Parents, Guardians, Educators, or Organizations

Where GenX Defenders is used through a parent, guardian, school, educator, training program, or other organization, we may receive information necessary to establish or manage the relationship.

For example, a parent or guardian may provide:

• their name;
• email address;
• telephone number;
• information necessary to verify or provide consent; or
• information about the child's account.

An educator or organization may provide information necessary to establish an educational or organizational account.

4. Information We Do Not Intentionally Collect From Children

Unless necessary for a specific feature and appropriately authorized, Ciphertainment does not intentionally collect:

• home addresses;
• precise GPS location;
• photographs or videos;
• biometric information;
• health information;
• financial information from children;
• government identification numbers;
• social media account credentials;
• contacts from a child's device;
• information about a child's friends or family; or
• sensitive personal information.

Players should never enter sensitive personal information into free-text fields, usernames, support requests, or other areas of the Game.

5. How We Use Information

We may use information we collect to:

• provide and operate GenX Defenders;
• create and maintain accounts where accounts are offered;
• save and restore game progress;
• provide game functionality;
• provide customer and technical support;
• respond to questions or requests;
• maintain the security of the Game;
• detect, investigate, and prevent fraud, abuse, cheating, or other misuse;
• identify and resolve technical problems;
• understand how the Game is being used;
• improve the Game and its educational content;
• develop new features and functionality;
• comply with applicable legal and regulatory requirements;
• enforce our Terms of Use; and
• protect the rights, safety, privacy, and security of Ciphertainment, our users, and others.

We do not use children's personal information for targeted advertising or behavioral advertising.

We do not use children's personal information to make decisions that produce significant effects on a child.

6. Educational and Game Improvement Data

We may use aggregated or de-identified information to understand how players interact with GenX Defenders and to improve the Game.

For example, we may analyze information such as:

• which missions are completed;
• which game features are used;
• overall gameplay trends;
• aggregated performance information; and
• technical performance of the Game.

Where information is aggregated or de-identified so that it cannot reasonably be used to identify an individual player, we may use that information for legitimate business, research, educational, analytical, and product-development purposes.

We will not use de-identified information to attempt to identify individual players.

7. Children's Personal Information

We do not sell children's personal information.

We do not knowingly use children's personal information for targeted or behavioral advertising.

We do not disclose children's personal information to third parties for their independent marketing purposes.

Where personal information from a child is collected, we limit its collection, use, and disclosure to what is reasonably necessary to provide, maintain, secure, support, or improve the Game, or as otherwise permitted or required by law.

Where applicable law requires verifiable parental or guardian consent, we will obtain that consent before collecting, using, or disclosing the child's personal information.

8. Parental and Guardian Consent

Because GenX Defenders is intended for children and young people, we may use age-based or other appropriate mechanisms to determine when additional privacy protections or parental/guardian involvement are required.

Where applicable law requires parental or guardian consent before we collect personal information from a child, we will take reasonable steps to obtain and verify that consent.

A parent or legal guardian may contact us to:

• ask what personal information we have collected about their child;
• request access to their child's personal information;
• request correction of inaccurate information;
• request deletion of their child's personal information;
• withdraw consent where applicable;
• request that we stop further collection or use of their child's personal information; or
• ask questions about our privacy practices.

Requests may be subject to reasonable verification procedures designed to protect the child's privacy and prevent unauthorized disclosure.

9. Information Sharing and Disclosure

We may disclose personal information in limited circumstances.

Service Providers

We may use carefully selected service providers to help us operate GenX Defenders and our business.

These providers may perform services such as:

• cloud hosting;
• application infrastructure;
• technical support;
• security monitoring;
• crash reporting;
• payment processing;
• customer support; and
• other services necessary to operate the Game.

Our service providers are expected to protect personal information and use it only for the purposes for which we have engaged them, subject to their contractual obligations and applicable law.

Legal Requirements

We may disclose information where we reasonably believe disclosure is necessary to:

• comply with applicable laws or regulations;
• respond to a valid legal process;
• respond to a lawful request from a government authority;
• investigate suspected fraud or abuse;
• protect the security of the Game;
• protect the safety, rights, or property of Ciphertainment, users, or others; or
• establish, exercise, or defend legal claims.

Business Transfers

If Ciphertainment is involved in a merger, acquisition, financing, reorganization, sale of assets, or similar transaction, personal information may be transferred as part of that transaction.

Where appropriate, we will take reasonable steps to ensure that personal information continues to receive protections consistent with this Privacy Policy.

10. Third-Party Services

GenX Defenders may use third-party services to provide certain functionality.

Before integrating a third-party service that collects personal information from children, we will assess whether the service is appropriate for the Game's intended audience and whether its collection and use of information are consistent with applicable privacy requirements.

Third-party services may have their own privacy policies. Where appropriate, we will identify significant third-party services and provide information about them.

We do not permit third-party advertising networks to use children's personal information for targeted advertising.

Important: The final published version of this Privacy Policy will identify the actual third-party services and SDKs used in the production version of GenX Defenders.

11. Advertising

GenX Defenders is designed without targeted or behavioral advertising directed at children.

We do not permit advertising providers to use children's personal information to create advertising profiles or deliver targeted advertising to children.

If advertising is introduced into GenX Defenders in the future, Ciphertainment will review the applicable privacy and child-safety requirements before implementation and will update this Privacy Policy as necessary.

12. Analytics and Tracking

We seek to minimize tracking technologies in GenX Defenders.

If analytics or diagnostic technologies are used, they will be limited to what is reasonably necessary to:

• understand technical performance;
• identify crashes and errors;
• maintain security;
• improve gameplay; and
• understand aggregate usage of the Game.

We will not use analytics technologies to create behavioral advertising profiles of children.

Any third-party analytics provider used in the production Game should be reviewed for compliance with applicable children's privacy requirements before deployment.

13. Security

Ciphertainment takes the security of personal information seriously.

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against:

• unauthorized access;
• unauthorized disclosure;
• alteration;
• loss;
• misuse; and
• destruction.

Depending on the nature of the information and the services involved, safeguards may include:

• encryption in transit;
• access controls;
• authentication mechanisms;
• restricted administrative access;
• security monitoring;
• secure development practices;
• vulnerability management;
• logging and monitoring; and
• policies and procedures governing the handling of personal information.

No method of transmission or storage is completely secure. Although we take reasonable measures to protect information, we cannot guarantee absolute security.

14. Data Retention

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, provide the Game, comply with legal obligations, resolve disputes, enforce agreements, and protect our legitimate interests.

Where personal information is no longer required, we will take reasonable steps to securely delete, destroy, or de-identify it.

We may retain limited information for longer periods where required by law or where necessary to establish, exercise, or defend legal claims.

15. Children's Account Deletion

A parent or legal guardian may request deletion of their child's account and associated personal information by contacting us.

When we receive a valid deletion request, we will take reasonable steps to verify the request and delete the applicable personal information, subject to:

• legal requirements;
• legitimate security requirements;
• fraud-prevention requirements; and
• information that must be retained for legal or operational reasons.

Deleting an account may result in the loss of saved game progress, achievements, or other account-related functionality.

16. Access and Correction

Individuals may have rights under applicable privacy laws to request access to personal information held by Ciphertainment and to request correction of inaccurate information.

Parents or legal guardians may exercise rights on behalf of a child where permitted by applicable law.

Depending on the circumstances and applicable law, we may need to verify the identity and authority of the person making the request before providing access to personal information.

17. International Processing and Storage

Ciphertainment and our service providers may store or process information in Canada or other countries where we or our service providers operate.

When personal information is transferred outside the jurisdiction in which it was collected, it may be subject to the laws of that jurisdiction.

We take reasonable steps to ensure that service providers handling personal information provide appropriate safeguards and use the information only for authorized purposes.

18. Privacy Breaches

Ciphertainment maintains procedures designed to detect, assess, respond to, and manage privacy and security incidents.

If a privacy breach occurs, we will assess the incident and take reasonable steps to contain and investigate it.

Where applicable law requires notification to affected individuals, parents or guardians, regulators, or other authorities, we will provide the required notifications.

19. Privacy by Design

Because GenX Defenders is designed for younger users, we consider privacy and child safety when designing new features.

When introducing new functionality that may involve personal information, we may assess:

• whether the information is actually necessary;
• whether the information can be collected anonymously or in de-identified form;
• whether parental involvement is required;
• whether the feature creates additional risks for children;
• whether third-party services are appropriate;
• how long the information needs to be retained; and
• what security controls are required.

We seek to collect the minimum amount of personal information necessary to provide the intended functionality.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• changes to GenX Defenders;
• new features;
• changes in technology;
• changes in applicable law;
• changes to our privacy practices; or
• improvements to our privacy and security program.

When we make material changes, we will take reasonable steps to provide appropriate notice.

The “Last Updated” date at the beginning of this Privacy Policy indicates when the policy was most recently updated.

21. Contact Us

If you have questions, concerns, or requests relating to this Privacy Policy or the privacy of a GenX Defenders player, please contact us.

For requests concerning a child's personal information, please indicate that the request relates to a GenX Defenders player who is under 18.

We may request reasonable information necessary to verify the identity and authority of the person making a request.

22. Privacy Complaints

If you have a concern about how Ciphertainment has handled personal information, we encourage you to contact us first so that we can investigate and attempt to resolve the concern.

Individuals in Canada may also have the right to contact the applicable privacy regulator, depending on the circumstances and jurisdiction.

For organizations subject to Alberta's Personal Information Protection Act (PIPA), individuals may have rights to request access to or correction of personal information and may make a complaint to the Office of the Information and Privacy Commissioner of Alberta.

23. Additional Protection for Young Players

GenX Defenders is intended to help young people learn cybersecurity in a safe and engaging environment.

Players should never share personal information such as:

• their full name;
• home address;
• school address;
• telephone number;
• passwords;
• photographs;
• precise location;
• financial information; or
• information that could identify another person.

Ciphertainment will never ask a player to disclose a password to another person through the Game.

Parents and guardians are encouraged to discuss online safety and responsible sharing of personal information with young players.

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