Updated September 13, 2022
Our Splats and App are generally intended to be used and enjoyed by children, teenagers, and adults of all ages. Our account creation and login features, however, are solely intended for creation and use by adults and education professionals. For this reason, we employ special measures when collecting or processing information and we generally avoid or limit the collection of Personal Information from Child-Users through their use of our Splats and App. For more details on our practices related to children, please see the section on Children’s Privacy below.
You do not have to share any Personal Information to access and view our Website.
If your child is a Classroom User, additional privacy protections apply because your Educational Institution may (but is not required to) provide us with Student Data (specifically and solely student name and/or class name) that is subject to the Family Educational Rights and Privacy Act. For more details on our practices related to Classroom Users, please see the section on Classroom Privacy below.
WHAT TYPE OF INFORMATION DO WE COLLECT AND WHY?
Collection of Information as a part of Customer Subscriptions:
During the registration process for any of our subscriptions, we ask the subscriber to provide us with a Customer name, email address, school or district affiliation (when applicable), phone number, and billing information. We use the information to create and service the account, fulfill the subscription and send you service-related announcements. For instance, we may send emails about routine maintenance, new feature launches, or product recommendations related to your subscription. We may also use this contact information to request feedback on our products and services, to inform future customer service and product improvements. You may opt out of promotional email messages at any time as described in the Opt-Out section below.
When engaging with Unruly through a paid subscription, schools or districts are required to appoint an administrator (“Administrator”), who is authorized by the school or the district to be responsible for the Students Records.
Each school or district Administrator has access to a dashboard that allows them to create, update, review, modify and delete individual accounts, and monitor logins within the individual accounts.
To create the teacher accounts, we require a Teacher’s full name, email address, school name, and app login provided by Unruly Studios. We may use the email address to send product updates and use recommendations, password recovery information, effectiveness and efficacy data, invitations to participate in surveys and research, and more. Teachers may opt-out of promotional email messages at any time as described in the Opt-Out section below.
If a school or district uses and accesses individual accounts through any of the single sign-on services that we support, we collect the information we use for the individual accounts function from such third-party integrated service.
Students’ accounts can be created by the school, the district, or by the teachers, or the teacher can invite the students to create the accounts using a school login provided by the teacher. We collect students’ usernames. Students will be able to store their saved games, game modifications, and game instructions within their individual accounts. Students cannot interact with other users outside their school or classroom subscription. No Student Personal Information is collected directly from students.
Other Information Collection:
Contact information for newsletter and surveys: Adult users may choose to sign up for newsletters, register for events, or participate in surveys, all of which require contact information. The submitted contact information will be used for promotional purposes, and you may opt out at any time. An opt-out link or instructions on how to opt-out will be included at the bottom of such messages. Registration for newsletters, events, and survey participation is not intended for minors.
Information we collect when you contact us: When you send us messages through our system or by email or through other online platforms, we collect the information you provide, including your message and any contact information you include. We use and retain such information to respond to your request, facilitate support to you in the future, and optimize our support services. We will respond once to messages from children under age 13 and then we delete those messages and any Personal Information contained in them.
Feedback: Certain features we offer include an option to provide us with feedback. The feedback feature does not identify the user submitting it. If we receive Personal Information through a feedback form we take steps to immediately delete that information. We reserve the right to use feedback for any purpose with no obligation to you.
Applying for a job: We will only use the information for the application process.
Information Collected Automatically
We automatically receive and record information on our server logs from a user’s browser. This may include the IP address, pages of Unruly visited, the time spent on those pages, and access times and dates. We use this information to better display our Services, maintain a user’s session, identify the country the user is located in, monitor, analyze the use of and administer Unruly, and to better tailor it to your needs. We may also use this information to serve advertising to adult users. We do not use student or children’s personal information for advertising purposes, including targeted advertising.
To learn about interest-based advertising, “lookalike audiences” and how you can opt-out of these features, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the Digital Advertising Alliance (DAA) resources at http://www.aboutads.info/choices. Note that if you wish to opt-out, you will need to do so separately for each of your devices and for each web browser you use. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at http://www.youronlinechoices.eu/. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
To collect this information, we use technological tools including:
Cookies. A cookie is a small data file sent from a website or application and stored on your computer or device. Cookies allow us to recognize your browser when you return to Unruly, remember your login information, and monitor potential account misuse. Cookies also allow us to better understand how you interact with Unruly and to monitor aggregated usage. You can set your browser to detect some cookies, to stop accepting cookies, or to prompt you before accepting a cookie. Disabling our cookies will limit some of the functionalities within our Services. To learn more about browser cookies, including how to manage or delete them, look in the Tools, Help, or similar section of your web browser, or visit allaboutcookies.org.
Pixel Tags. A pixel tag (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one pixel – that we place in our marketing emails, newsletters, promotional offerings, and surveys. We use pixel tags and line tracking to analyze the effectiveness of our marketing campaigns.
By using our Services, you agree to our use of these tracking technologies.
In addition, we and our third-party partners may use tracking technologies to deliver targeted advertisements and marketing messages to adult users on our or unaffiliated websites and online services.
We also subscribe to various third parties’ education market information and databases, for example, databases of school contacts. We use this data to learn about the industry we serve, to improve our services, and for direct marketing. Some third parties may provide us pseudonymised information about you (such as demographic information or sites where you have been shown ads) from offline and online sources that we may use to provide you with more relevant and useful advertising.
How Long We Retain Personal Information:
Districts and schools and homeschools can delete student Personal Information at any time and in real-time using the Administrator dashboard as mentioned above. Once that information is deleted, it is deleted from our servers – first from our servers and then, five weeks later, from any backup server. If information was not deleted by the school or the district before the subscription expired, we retain such information for a limited period of 3 months after expiration.
Student classroom accounts and the student identifiable information within them are automatically deleted after three months of inactivity - first from our server and then, two weeks later, from any backup server. At that point it cannot be restored.
If your jurisdiction requires the deletion of student data within a shorter time period, or immediately upon termination of the subscription, you are required to delete such data using the Administrator dashboard as mentioned above or contact us for assistance at firstname.lastname@example.org.
Districts and schools may request copies of their student personal information (which includes a CSV template file of names, and classes), which shall be provided within four (4) weeks of the written request.
We may retain, use and share anonymous or aggregated and de-identified information for lawfully permissible purposes, including developing and improving educational products and services, educational research purposes, evaluating, informing and demonstrating the effectiveness and efficacy of our products and services.
How We Share Your Information
We may provide Customer Personal Information to our partners, business affiliates, and third-party service providers who work for Unruly and operate some of its functionalities. These may include hosting, streaming, credit card processing services, and companies that provide marketing emails on our behalf. A current list of these third parties service providers is available to our subscribers upon request through email@example.com. These third parties service providers are bound contractually to practice commercially reasonable security measures and to use your personal information solely as it pertains to the provision of their services. They do not have the independent right to share your Personal Information or use it for any unrelated purposes.
We reserve the right to disclose Personal Information if we are required to do so by law, or if we believe that disclosure is necessary to protect our rights, protect your safety or others' safety, investigate fraud, and/or comply with a judicial proceeding, court order, subpoena, or legal process.
HOW WE PROTECT THE INFORMATION WE COLLECT: SECURITY
Unruly Studios maintains commercially reasonable physical, electronic, and procedural safeguards designed to protect Personal Information.
Your Personal Information may be stored on our behalf on third-party cloud infrastructure provider Amazon Web Services (AWS), a service provided by Amazon Web Services Inc. You can find more information about Amazon Web Services’ security practices online.
We apply a Secure Sockets Layer (HTTPS) encrypting technology to encrypt data in transit
Governance policies and access controls are in place to ensure that the information of each district, school, or other subscriber is separated, and all subscribers can only access their own data.
We are committed to maintaining the security and confidentiality of any Student Data, which we receive from Educational Institutions for Classroom Users. Some of the precautions we take include (a) limiting employee access to Student Data to only those employees with a need to such access to fulfill their job responsibilities; (b) requiring employees to sign confidentiality agreements upon hiring; and (c) protecting Student Data with technical, contractual, administrative, and physical security safeguards.
Only limited Unruly personnel have access to the database, and personnel only access it when necessary to provide services. Personnel with access to Student Records pass criminal background checks and undergo periodic privacy training.
In the unlikely event that an exposure of Student Data is suspected, on-call responders will follow our internally published Incident Response Plan, describing how incidents are identified, classified (low, high, critical), verified, and how a team is assembled to respond and communicate to outside parties. The Incident Response Plan is reviewed and rehearsed on a quarterly basis by Engineer Operations. If Unruly determines that a Breach has occurred, we will notify affected customers promptly and will cooperate with customers as needed to enable compliance with all state breach of confidentiality laws.
While we strive to maintain industry-standard privacy and security practices and we have in place technical and organizational means to protect your Personal Information, it should be noted that no industry system which includes data transmission over the Internet or data storage can be guaranteed to be 100% effective, and Unruly is not responsible for security incidents not reasonably foreseeable or reasonably within our control. In the event of unauthorized access to Personal Information, we will promptly notify the affected subscriber(s) in accordance with applicable law, and as appropriate, coordinate with the subscriber to support notification of affected individuals, students, and families. If you have reason to believe that any interaction with us is not secure (i.e., if you feel that any form of digital communication or interaction with us or one of our products has been compromised), please immediately notify us of the problem by contacting us at firstname.lastname@example.org
We care about children’s privacy and are committed to complying with the Children’s Online Privacy Protection Act (COPPA). Please note that our Splats are designed to be usable by children, teenagers, and adults of all ages. In compliance with COPPA, Unruly does not collect Personal Information from children under 13 without a parent or guardian's consent or that of a school if applicable. Parents and guardians of children under 13 who use any of the Unruly products have certain rights under COPPA and Unruly recognizes those rights. At any time, parents/guardians may request to review the personal information we collected from their child, request that we make no further use of that information, or request that we delete it. To exercise your right to delete information, please contact your school to exercise your rights and we will work with the parent/guardian and school together to facilitate those requests.
In some instances, we may collect a limited amount of Personal Information from a parent or educator, or Child User (such as an email address) and use such information for a one-time event or communication (e.g., one-time contest, share your code submission, etc.) or for multiple ongoing communications to a Child User (e.g., email alerts, push notifications). For these types of activities, we may rely on exceptions to the parental consent requirement under COPPA or follow other procedures to ensure compliance (e.g., removal of Personal Information prior to collection or immediately after use, a parental notification with opt-out mechanism, local storage of the information with no uploading to the web, etc.).
Students cannot interact with other users outside their school or classroom subscription using our Services, including our Splats and App.
Some features on our App or Splats may allow the local storage of information on your device (including Personal Information such as voice recordings), without the uploading of such information to the web or our servers.
We may collect and process Product Use Information and Browsing Information from a Child User through the use of our Splats, but only for purposes of reporting data back to the educational institution that owns the account (and users such as educators and admins), and supporting our internal operations, such as to help us:
We will not use Product Use Information or Browsing Information, collected through the use of our Splats and App, for behavioral or re-targeted advertising purposes or allow third parties to track the activity of a Child User for such purposes.
With proper authentication, a parent, legal guardian, or educator always has the right to review the Personal Information we may have collected and stored about their child, request deletion of such Personal Information, or refuse to allow further collection or use of such information by Unruly Studios. Please keep in mind that a request to delete such information may limit the child’s and account holder’s access to all or a portion of our Services. If you believe that a child under 13 might have provided us with Personal Information without your permission, or if you wish to view, request deletion of, or prohibit further collection of information about your child, please contact us at email@example.com. We urge parents, guardians, and educators to monitor children’s use of all digital media.
If your child is a Classroom User, please contact your Educational Institution if you need to request to access, make changes to, or delete Student Data on your Classroom User from our servers. Any request to access, make changes to, or delete Student Data must be made by the Educational Institution’s designated administrator for the Classroom User. The administrator will be provided access to the Classroom User’s account in order to update, correct, or delete the information contained therein.
Parents and guardians of Classroom Users should contact their respective Educational institutions for any questions regarding account cancellation and data deletion.
LINKS TO OTHER WEBSITES
We do not link to third-party websites from our Website or our App. We are not responsible for the practices employed by websites or services that choose to link to our Website, including the information or content contained therein. We encourage our users to familiarize themselves with the privacy statements of all websites and apps that they visit and interact with.
CALIFORNIA PRIVACY RIGHTS
As a California resident, you have certain rights regarding your personal information. These rights include:
In order to prevent unauthorized access to your information, we are required by law to verify your identity before we may address your request.
To Exercise Your Rights
Unruly is used in schools at the direction of our Customers. In addition, we are obligated under FERPA to remain under the direct control of our Customers with respect to our use and maintenance of student personal information that is part of the education record. As such, if you use Unruly through a school account and wish to exercise your rights in respect to student personal information, please contact your education institution and we will work with them to facilitate your request.
All other Unruly users and visitors may exercise these rights by:
Your exercise of the above rights is subject to certain exemptions to safeguard the public interest and our interests. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. Where required by applicable law, we will notify you if and why we are unable to fulfill your request.
Non-discrimination: We shall not discriminate or otherwise penalize anyone for exercising their rights.
Categories of Personal Information we may collect
Categories of sources from which the Personal Information is collected
Purpose for collection of Personal Information
We collect your Personal Information to provide the services as follows:
We only share Personal Information with service providers who support us in delivering the Services as described above.
Specific pieces of Personal Information we have collected
Administrators and educators: full name, email address, phone number, username, password, security question, school, school address, classes associated with the account, IP address
Students: username, password, IP address
Connecting with Unruly: name, email address, other contact information, IP address
Website visitors: IP address, pseudonymous end user identifiers
Authorized Agent: California residents may use an authorized agent on their behalf to exercise a privacy right discussed above. If you are an authorized agent acting on behalf of a California resident to communicate with us or to exercise a privacy right discussed above, you must be able to demonstrate that you have the requisite authorization to act on behalf of the resident and have sufficient access to their laptop, desktop, or mobile device to exercise these rights digitally. If you are an authorized agent trying to exercise rights on behalf of an Unruly user, please contact the user's school or district with supporting verification information, which includes a valid Power of Attorney in the State of California, proof that you have access to the user’s device, and proof of your own identity.
Users who are California residents may request and obtain from us once a year, free of charge, certain information about the Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with whom we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to firstname.lastname@example.org.
VISITORS RESIDING OUTSIDE THE UNITED STATES
WHAT CAN I DO TO HELP PROTECT PRIVACY WHILE USING THE APP?
Please do not share personal contact information (such as your name, physical address, email address, or phone number) in projects, comments, profiles, studios, or forum posts. Please let us know if you see this kind of information by emailing us at email@example.com It is also important that you maintain the security and control of your account credentials, and not share your password with anyone outside of your school or organization.
If you have subscribed to receive marketing messaging from us, or if you receive an unwanted email from us, you can opt-out of receiving future emails by clicking the opt-out link in the email or alternatively by sending an email to firstname.lastname@example.org, with “Opt-out” in the subject line. We will process your request within a reasonable time after receipt. Note that you will continue to receive operational emails regarding the products or services you are subscribed to.
If we make a material change in the way we handle previously collected Personal Information of our users, we will notify you more prominently and request your consent or the consent of a parent or legal guardian, as applicable and legally required.
If you have any remaining questions about how we treat your privacy, just let us know. You can contact us by writing to us at email@example.com or Privacy Manager, Unruly Studios, Inc., 50 Milk St Floor 16 Boston, MA 02110.
50 Milk St Floor 16
Boston, MA 02110