California, EU, and Canada Privacy Rights
Please note that Alter-Learning Educational Platform, Inc., has placed a new California Notice of Rights on its website to explain how California residents may exercise their privacy rights under the California Consumer Privacy Act. This notice is incorporated into this policy. Generally, under this new law, California residents have the right to know what Alter-Learning Educational Platform, Inc., is Sharing with third parties for direct marketing purposes. California residents have the right to request the identity of any third parties to whom the resident’s personal information was shared, if such sharing was to enable the third party’s direct marketing efforts. If you are a California resident and wish to make such a request, please submit your request to https://alter-learning.com/ OR to opt-out of having your personal information shared with third parties for their direct marketing purposes, please email us at:
As California Resident you have the right to:
- A right to transparent notice about the collection of your data;
- A right to know what personal information Alter-Learning Educational Platform, Inc., holds about you including where we obtain it and the categories of third parties with whom we share it;
- A right to request deletion of personal information in certain circumstances;
- A right to opt-out of sales of personal information;
- An ability to appoint a third-party representative to assist you with exercising your rights and;
- A right not to be discriminated against for exercising your rights.
Please note Alter-Learning Educational Platform, Inc., does not discriminate in its provision of services to you based on exercising your rights.
Your requests to delete data is limited to data that Alter-Learning Educational Platform, Inc., is not allowed to retain under the CCPA. Alter-Learning Educational Platform, Inc., may retain data for certain purposes, including completing transactions for you or reasonably related to completing transactions for you, detecting security incidents, illegal activity and fraud, maintaining our systems, complying with applicable law and legal obligations, engaging in public or peer reviewed research provided we comply with applicable ethics and privacy laws related to such research, or enabling solely internal purposes such as financial recordkeeping.
You may ask a third-party representative to assist you in exercising your rights. Third parties may write to https://alter-learning.com/ to provide documentation of their right to act on your behalf. If you are a game player, we will not have a way to locate records about your outside of an app using Alter-Learning Educational Platform, Inc., software, but you may direct your reports to be sent to your representative once you have verified your identity inside of the app. Alter-Learning Educational Platform, Inc., account holders may also send data reports obtained through your account directly to your representative. You need only to provide their email or mailing address instead of your own when ordering. For third party representatives writing in on behalf of Alter-Learning Educational Platform, Inc. account holders, please provide the name and any signed documentation you may have to act on behalf of the account holder, or you may ask the account holder to write to us from their account email to provide us permission to transact with you directly. Alter-Learning Educational Platform, Inc., reserves the right to take reasonable steps to verify the authenticity of identities and authorizations in compliance with applicable laws prior to making any disclosures.
More information on your rights as a Californian and instructions on how to exercise them with Alter-Learning Educational Platform, Inc., may be found here.
You may view our CCPA Transparency Report at https://Alter-Learning.com/ This report provides details on our responses to requests to access, delete or opt-out under CCPA.
How we respond to “Do Not Track” signals: We are committed to providing you with meaningful choices about the information collected on our Services for third-party purposes, and that is why we provide information in our Cookie Policy about how to prevent the delivery of targeted ads, and information in this policy about how to prevent Google Analytics and Twitter from collecting information. We do not, however, recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions. To learn more about Do Not Track signals, you can visit allaboutdnt.com.
If you are a European Union resident, the General Data Protection Regulation provides certain rights to you with respect to your personal data. Where is a data controller, you have the following rights:
- Right to Access – You have the right to request Alter-Learning Educational Platform, Inc., provide you with a copy of your personal data.
- Right to Rectification (Correction) – You have the right to request Alter-Learning Educational Platform, Inc., to correct any information about you that you believe is incorrect. You also have the right to request Alter-Learning Educational Platform, Inc., to complete information about you that you believe is incorrect.
- Right to Erasure (Deletion) – You have the right to request Alter-Learning Educational Platform, Inc., to erase your personal data, under certain conditions.
- Right to Restrict Processing – You have the right to request Alter-Learning Educational Platform, Inc., to restrict the processing of your personal data, under certain conditions.
- Right to Object to Processing – You have the right to object to Alter-Learning Educational Platform, Inc., processing of your personal data, under certain conditions.
- Right to Data Portability – You have the right to request Alter-Learning Educational Platform, Inc., to transfer your personal data that we have collected to another organization, or directly to you, under certain conditions.
The Canadian Personal Information Protection and Electronic Documents Act provides certain rights with respect to your personal data, such as:
- Right to Access – You have the right to request Alter-Learning Educational Platform, Inc., provide you with a copy of your personal data.
- Right to Rectification (Correction) – You have the right to request Alter-Learning Educational Platform, Inc., to correct any information about you that you believe is incorrect. You also have the right to request Alter-Learning Educational Platform, Inc., to complete information about you that you believe is incorrect.
To exercise the above rights, email: data@alter-learning.com, or visit https://alter-learning.com/ (or contact us as indicated in the ‘Contact Us’ section below). In some cases, a Alter-Learning Educational Platform, Inc., customer, such as a game developer, may be the controller of your data and Alter-Learning Educational Platform, Inc., only a Processor. In this case, Alter-Learning Educational Platform, Inc., will direct you to its customer, and Alter-Learning Educational Platform, Inc., will support its customers in responding to requests as required by law.
In addition, where our processing activities in respect of your Personal Data are subject to the GDPR, you may lodge a complaint with a European Union supervisory authority. If you do have a complaint, we would appreciate the chance to deal with your concerns before approaching your supervisory body, so please contact us at https://alter-learning.com/ if you wish to discuss any complaint. You can find your supervisory authority here.
Do Not Sell My Personal Information
NOTICE TO CALIFORNIA RESIDENTS REGARDING CALIFORNIA CONSUMER PRIVACY ACT EFFECTIVE JANUARY 2020
Welcome to https://alter-learning.com/ quick start information guide on how to exercise your rights under the California Consumer Privacy Act (CCPA). Alter-Learning Educational Platform, Inc., recognizes that there are many different users of Alter-Learning Educational Platform, Inc., – game players, developers, etc. This page provides important notices and directions for different users to exercise rights under the CCPA. For more information on Alter-Learning Educational Platform, Inc., view of data collecting and use practices, please view Alter-Learning Educational Platform, Inc., Privacy Policy and to learn more about Alter-Learning Educational Platform, Inc., and CCPA please visit Alter-Learning Educational Platform, Inc., CCPA and Data Privacy.
Does Alter-Learning Educational Platform, Inc., actually “sell” personal information?
https://alter-learning.com/ does not, and will not, provide your personal information in direct exchange for money. Therefore, in the literal sense, Alter-Learning Educational Platform, Inc., does not sell your data. However, the CCPA requires Alter-Learning Educational Platform, Inc., to disclose if it sells personal information and under the CCPA’s expansive definition of “sell”, the following activities may constitute a CCPA sale of data.
Alter-Learning Educational Platform, Inc., Ads
Many games include advertisements. When you play a game that utilizes Alter-Learning Educational Platform, Inc., Ad Network, the device you are using sends an advertising identifier (called an “Ad ID”) to Alter-Learning Educational Platform, Inc., Under the CCPA, this Ad ID is considered personal information. Why? Because it may include information on you such as your location, the device you are using, some of the activities you’ve completed in your game and more. We have included the full list of “personal information” below for your convenience.
Alter-Learning Educational Platform, Inc., shares the Ad ID with our advertising and publishing partners and sometimes our partners may use this Ad ID to look up information about you. This may include things like your online activities, purchases you’ve made or websites you’ve visited. This is all done to personalize future advertisements you may see. In fact, the whole point is to give the advertiser an opportunity to advertise to you – and specifically to you – with a personalized ad. For this reason, under CCPA, sharing the Ad ID may be a sale of personal data.
If you do not see these options, your developer has enabled privacy controls to create a more privacy-protective experience or to indicate that this app is directed to children under the age of 13. As a result, we deliver ads to you based only on contextual data (e.g., the game you are playing).
Alter-Learning Educational Platform, Inc., Analytics
If you are playing a game that uses Alter-Learning Educational Platform, Inc., Analytics enabled, then, yes, Alter-Learning Educational Platform, Inc., is collecting personal information on you. While this is controlled on the publisher side, you do have the ability to opt out of data collection. Please note that Alter-Learning Educational Platform, Inc., does not believe the usage of analytics by your developer is a “sale” of personal information; however, we have offered the opt-out opportunity to this service. To access your privacy settings, look for your privacy information and account services (each location will be different in each game) and if you have trouble finding it, contact the games provider. Once you begin to exercise your privacy rights, you will, however, be pushed into the new Alter-Learning Educational Platform, Inc., web flow that will guide you through the process.
Website Cookies
The other activity that may constitute “selling” personal information is with cookies. Alter-Learning Educational Platform, Inc., sets cookies when you visit our website, and some may be shared with certain third-party marketing partners in order for us to reach you with new offers. You can get full information on our Cookie Policy here. Sharing cookies with certain third parties may be considered a “sale” under the CCPA.
Ok, if I’m a game player, under CCPA, what rights do I have?
As a game player, you have the right to opt out from personalized ads, request the deletion of certain personal information, and/or request a data disclosure of your personal information from Alter-Learning Educational Platform, Inc.. In general, Alter-Learning Educational Platform, Inc., does not have enough information about you as an individual to locate your records or verify your identity through an email or mailed request. Therefore, we have created an alternative way for you to authenticate yourself for a CCPA data disclosure when you are inside of a game. You may also exercise your opt-out inside an app without going through the formal verification.
Please note if you do not see opt-out options in your app, your game developer has enabled privacy controls to create a more privacy-protective experience or to indicate that the app is directed to children under the age of 13. When this is done, we deliver ads to you based on contextual data (e.g., the game you are playing) instead of your personal information.
What does this look like?
To exercise your rights under CCPA, you can start by clicking on the privacy settings banner or at any time by clicking on the privacy icon in the left bottom corner of a Alter-Learning Educational Platform, Inc., ad. The icon looks like this:
Privacy icon
Once you click on this icon, you will be guided through a series of steps to achieve the changes or requests you prefer.
You can opt-out of personalized ads inside of the game you are playing, or, if you provide your preferred email and go through verification inside the ad, you can get a link to order a data disclosure report or opt-out of personalized ads for the game you are playing at that time. We will not use your email for any purpose other than helping you exercise your privacy rights.
What if I am a Alter-Learning Educational Platform, Inc., developer, what rights do I have?
As a Alter-Learning Educational Platform, Inc., developer, you have a right to request the deletion of certain personal information, and/or request a disclosure of personal information from Alter-Learning Educational Platform, Inc.. You may do this in the privacy settings of your account. Please note Alter-Learning Educational Platform, Inc., cannot delete certain personal information it uses for business purposes, including billing and payment records, license verification, fraud prevention information, and data to assure security and integrity of our systems. We do not share developer account information in any way that constitutes a “sale” of data under California law; however, we permit you to opt-out of certain uses of your personal information, such as contributing information to certain internal usage statistics analysis.
How do I exercise my rights?
If you are a Alter-Learning Educational Platform, Inc., developer, please log in to your account and view your privacy settings page to obtain data disclosures and adjust your privacy settings
I am just visiting the Alter-Learning Educational Platform, Inc., website. What rights do I have?
We have included the means for you to opt-out when you visit our website. Look for the pop up on the website, and select your options. We do not have a way yet to authenticate website visitors for disclosures of personal information. We will continue to review this from time to time and update this notice if we create a way to do this. We encourage you to visit the privacy pages with our third-party partners listed in our Cookie Policy to determine if they have an ability to provide you a disclosure.
The processes for exercising your rights described in this notice should appear in the apps you use containing Alter-Learning Educational Platform, Inc., services and on our website. Contact https://alter-learning.com/ if you have any questions.
SUMMARY OF ALTER-LEARNING EDUCATIONAL PLATFORM, INC. PERSONAL INFORMATION COLLECTION AND USE PRACTICES
The following is a summary of Alter-Learning Educational Platform, Inc., personal information collection and use practices. You can find more information and details on Alter-Learning Educational Platform, Inc., Privacy Policy.
Categories of Personal Information Collected
Depending on the type of interaction you have with Alter-Learning Educational Platform, Inc., Alter-Learning Educational Platform, Inc., may collect information in some or all of the categories of personal information listed below:
Identifiers, such as name, signature, contact information, online identifiers, and government-issued ID numbers;
Personal information, as defined in the California customer records law, such as name, contact information, payment card number, medical information, insurance information, education information, employment information, and government-issued ID numbers;
Characteristics of protected classifications under California or federal law, such as sex, age, race, disability, and marital status;
Commercial information, such as transaction information and purchase history;
Internet or network activity information, such as browsing history and interactions with our website;
Geolocation data, such as device location and IP location;
Audio, electronic, visual, and similar information, such as call and video recordings;
Professional or employment-related information, such as work history and prior employer;
Education information; and
Inferences drawn from any of the Personal Information listed above to create a [profile/summary] about, for example, an individual’s preferences and characteristics.
Other Data – Information is more specifically laid out and described in our full Privacy Policy.
Source of the Personal Information Collected
Alter-Learning Educational Platform, Inc., collects personal information directly from you as an Alter-Learning Educational Platform, Inc., user as well as from sources from the categories of sources listed below:
Developers
Marketers
Third-Party Social Networks
Alter-Learning Educational Platform, Inc., Partners
Researchers
Your personal information listed above may be collected from you automatically by Alter-Learning Educational Platform, Inc., from the device you’re using to access and play games developed using Alter-Learning Educational Platform, Inc., software or services.
How Alter-Learning Educational Platform, Inc., Uses the Personal Information it Collects (Intended Use Purposes)
Alter-Learning Educational Platform, Inc., primarily uses the personal information collected to provide, administer, operate and improve our services. We may use your information for the following purposes:
Provide our services to you;
Offer technical support and respond to your inquiries;
Personalization;
Process payments;
Marketing and promotions;
Analytics and improvement;
Prevent fraud, enforce the relevant terms of service or licenses, and protect users;
Identify and suggest connections with other users;
Permit game players wishing to play connected games to be matched with other players via Multiply or other connected games services;
Create and share statistics and reports regarding aggregate usage of Alter-Learning Educational Platform, Inc., -powered apps;
Enable user-to-user communications;
Link to or combine with other information we have gathered;
Deliver and target advertising, including personalized ads;
Conduct business intelligence research and analytics; and
Comply with legal obligations: As we believe it is necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
Right to Delete Personal Information
All of the above are internal business purposes under CCPA with the exception of the profiles described on this page related to targeted advertising to game players and our website visitors, which may constitute a “sale” under CCPA. You may have the cookies and related profiles that Alter-Learning Educational Platform, Inc., holds deleted about you with respect to those uses of the cookie or AD ID; otherwise, Alter-Learning Educational Platform, Inc., needs the information to carry out the internal business purposes described herein, including billing, fraud prevention, securing our systems, and assuring their integrity.
Where Alter-Learning Educational Platform, Inc., Shares the Personal Information, it Collects (Categories of Third Parties to whom Personal Information is Disclosed)
Alter-Learning Educational Platform, Inc., only discloses your personal information for the purposes described above with certain third parties, including:
Alter-Learning Educational Platform, Inc., Affiliates and Subsidiaries
Third-party Service Providers
Asset Store Sellers and Verified Solution Partners
Developers
Advertising and Related Publishers; Third Party Ad Network Partners listed in our Privacy Policy, which can be found at https://alter-learning.com/
Verified third parties (when necessary to ensure safety, security, compliance with a legal obligation, or in the event of a merger, acquisition by another company, transfer of control, or sale of all or a portion of its assets).
How to Contact Us
If you have questions about how we collect, store and use Personal Information, please contact us at the following:
Consumer Rights Webform: Email: consumerrights@alter-learning.com
Phone:
Aldi: 530-601-8275
Mail:
For the Attention of Alter-Learning Educational Platform, Inc., Guest Service,
2748 Ganges Place, Davis, CA 95616