Updated April 2023
Play Roly is a learning tool operated by Teaching the Way They Learn Corporation (“Play Roly”, “we”, or “us”), including the Play Roly Desktop Application (the “Desktop App”) and the Play Roly Mobile Application (the “Mobile App”) (together, the “Apps”) We respect your privacy and is committed to protecting the personal information you may provide to us while using or accessing our services, using our website, or by voluntarily interacting with us.
All references to the term “you” or “parent” in this Policy shall include legal guardians, and all references to “children” or “child” shall mean children under 13 years of age. Use of Play Roly and the Apps involves collection of personal information about children, and we obtain parental consent to do so in accordance with COPPA and/or the General Data Protection Regulation (“GDPR”). By creating an account, you are certifying that you are the parent or legal guardian of the child and are authorized to provide such consent.
- Meaning of Personal Information
- Your Consent to Collection, Use and Disclosure
- Personal Information We Collect
- Non-Personal Information We Collect
- How We Use Your Personal Information
- How We Share Your Personal Information
- Third Party Websites and Services
- Opting Out of Communications
Generally speaking, under Canadian privacy laws personal information does not include any business contact information that is solely used to communicate with you in relation to your employment, business, or profession, such as your name, position name or title, work address, work telephone number, work fax number, or work electronic address.
Your consent to collection, use, and disclosure
Where appropriate, we collect, use, and disclose your personal information with your consent or as permitted or required by law. How we obtain your consent (i.e., the form we use) will depend on the circumstances, as well as the sensitivity of the information collected. Subject to applicable laws, your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question. If you choose to provide personal information to us, we assume that you consent to the collection, use, and disclosure of your personal information as outlined in this privacy statement.
Typically, we will seek your consent at the time your personal information is collected. Where we want to use your personal information for a purpose not previously identified to you at the time of collection, we will seek your consent prior to our use of such information for this new purpose.
If you provide personal information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use, and disclose his or her information as described in this Policy. If you provide personal information about another individual to us, and in particular about a child or children by creating an account, you warrant that you are a parent or legal guardian and have the authorization and capacity to provide consent to enable us to collect, use, and disclose his or her information as described in this Policy.
You may withdraw your consent to our collection, use or disclosure of your personal information at any time by contacting us using the contact information in the “Contact Us” section below. However, before we implement the withdrawal of consent, we may require proof of your identity. In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain products or services, including access to the Apps.
Personal information we collect
The personal information we collect is generally in one or more of the following categories:
A. The Desktop Ap
Information we collect directly:
- Account management and profile information: we collect information from parents and/or legal guardians when they create an account to use the Desktop App, request our newsletter, request customer support, leave feedback, or otherwise communicate with us. The types of information we may collect include first and last name, nature of relationship to the child, email address, country, state/province/region, password, date of birth, child’s full name, child’s gender, child’s date of birth, child’s spoken language and language preferences, and any other information parents choose to provide, such as a profile photo for their child.
- Performance information: we collect information from parents as they complete program milestones and work through the App’s modules, including information about the child’s performance. Upon completion of the program, a Certificate of Completion is generated.
Information We Collect Automatically:
- Log and Usage Data: We may collect log and usage data relating to a user’s use of the Desktop App, such as a user’s device information and information about a user’s activities on the Desktop App. We may also collect in-App analytics which may include geographical information.
B. The Mobile App
Information we collect directly:
- Account management and profile information: we collect information from parents and/or legal guardians when they create an account to use the Mobile App, request our newsletter, request customer support, leave feedback or otherwise communicate with us. The types of information we may collect include first and last name, nature of relationship to the child, email address, country, state/province/region, password, date of birth, child’s full name, child’s gender, child’s date of birth, child’s spoken language and language preferences, and any other information parents choose to provide, such as a profile photo for their child.
- Performance information: we collect information from parents as they complete program milestones and work through the Mobile App’s modules, including information about the child’s performance. Upon completion of the program, a Certificate of Completion is generated.
Information We Collect Automatically:
- Log and Usage Data: We may collect log and usage data relating to a user’s use of the Mobile App, such as a user’s device information and information about a user’s activities on the Mobile App. We may also collect in-App analytics which may include geographical information.
C. The Website
For individuals who visit our website located at https://www.playroly.com/ and its related subpages (collectively, “our website”), we may collect information from you or from your activities on the website.
Information we collect directly:
- When you register, create, and populate your account, we may collect your name, email address, telephone number, password, residency status, age, and contact information.
- When you submit an inquiry through the website, we may collect information you submit directly to us through the website, including your name, email address, and/or other contact information.
- When you sign up for our email list or newsletter, we collect your name, email address, and/or other contact information.
Information we collect automatically:
- Like most websites and other Internet services, we may collect certain technical and device information about your use of our website. Such information may include your Internet protocol address (“IP address”), information about your device (e.g., model or operating system), browser and operating system, and the date and time of your visit. We may also collect or infer your geographic location based on your IP address.
D. Other Interactions
For individuals who otherwise interact with us, whether in person, by phone or email, through social media or otherwise, including individuals who might be interested in acquiring our products or services, who sign-up to receive newsletters or other communications, or who respond to surveys and questionnaires, we may collect information that you provide to us during these interactions. This information may include your name, email address, and other contact information.
By providing personal information to us, you voluntarily consent to the collection, use, and disclosure of such personal information as specified in this Policy. Without limiting the foregoing, we may on occasion ask you to consent when we collect, use, or disclose your personal information in specific circumstances. Sometimes your consent will be implied through your conduct with us if the purpose of the collection, use or disclosure is obvious, and you voluntarily provide the information.
What other information we collect from you
General, aggregated, demographic, and non-personal information may be collected by us through the website or Apps, but any such information will not be linked to any of your personal information. This type of anonymous, aggregated profiling and session data may include information that you have provided to us through surveys, polls, etc., and may also include aggregated anonymous information about App usage and the customer base.
How we use your personal information
We use the information we collect from parents and children using the Apps and our website to maintain, analyze, and improve our products and services, including to:
- Create your account(s) and facilitate the use of the Apps;
- Provide customer service and technical support;
- Respond to your comments, questions, and requests, and otherwise facilitate or contact you about your or your children’s use of the Apps;
- Contact you relating to our products and services;
- Notify you about important changes to the Apps and applicable terms and policies;
- Monitor, analyze trends, usage and activities in connection with the Apps, and improve and personalize the Apps, and to develop new products and services;
- Monitor and analyze trends, usage and activities in connection with our website, and personalize and improve our website;
- Analyze the needs and activities of our users and customers to help us better serve them;
- Conduct research and analysis related to our business, products and services;
- Respond to inquiries and other requests;
- Provide you with information that we think may interest you, including in regards to our products and services, and to communicate with you about marketing aspects such as products, services, offers, and events offered by Play Roly and others, and provide news and information we think will be of interest to you;
- Protect the rights, property or personal safety of you, us, our users and the public;
- Enforce this Policy or our Terms of Service;
- Detect, investigate, and prevent fraud or potentially illegal activities and protect the rights and property of Play Roly and others;
- Investigate legal claims; and
- Carry out any other purpose for which consent is obtained, or as otherwise permitted or required or authorized by applicable laws.
We may occasionally communicate with you regarding the Apps or other offerings we believe might be of interest to you. You have the option to not receive this information. We provide an opt-out function within all email communications of this nature, or alternatively, we will cease to communicate with you for this purpose if you contact us and tell us not to communicate this information to you.
Whatever the purpose may be, we will collect and process your personal information to the extent you have provided us with your consent, or alternatively as reasonably necessary to fulfill our contracts with you, perform our legitimate business objectives, or as may be required by applicable law. We may use your personal information and other information for purposes for which we have obtained your consent and for such other purposes as may be permitted or required by applicable law.
- With vendors, consultants, and other service providers who need access to such information to carry out work on our behalf;
- In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;
- If we believe an individual’s actions are inconsistent with the spirit or language of our user agreements or policies, or as we believe is appropriate to protect the rights, property and safety of Play Roly, our users, or others;
- In connection with, or during negotiations of, any merger, sale of company assets, joint venture, financing or acquisition, or in any other situation where personal information may be disclosed or transferred as one of the business assets of Play Roly. We may share aggregated or anonymized information that does not constitute personal information, such as sharing analytics and other aggregate information about users’ activities that do not contain any personal information;
- For any other purpose for which consent is obtained; and
- Additionally, we may use and disclose your information when we believe such use or disclosure is permitted, 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 the terms of the agreements for our products and services; (e) to protect our operations or those of any of our affiliates or subsidiaries; (f) to protect our rights, privacy, safety or property, and/or those of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
Third party websites and services
This Policy applies only to our websites and products. It does not extend to any websites, products, social media platforms, or services provided by third parties.
We rely on third party services providers to perform a variety of services on our behalf. This may include technical support providers, hosting, data storage and processing service providers, and research and analytics providers. If we provide your information to service providers, then we require that the service providers maintain the confidentiality of your personal information and keep your personal information secure. We also require that they only use your personal information for the limited purposes for which it is provided. When our service providers no longer need your personal information for those limited purposes, we require that they dispose of the personal information. In some circumstances, we may permit our service providers to retain aggregated, anonymized, or statistical information that does not identify you. We do not authorize the service providers to disclose your personal information to unauthorized parties or to use your personal information for their direct marketing purposes.
There may be times where a third party may ask to collect your personal information themselves. These third parties can include advertisers and third party service providers and payment processors. When you provide your personal information to such third parties, they will use your personal information in accordance with their own privacy policies and not this Policy. Therefore, you should read their privacy policies carefully before providing them with your personal information. We are not responsible for the privacy practices of such third parties, and we encourage you to review all third party privacy policies prior to using third party websites or products or services.
The third party service providers we use, includes but is not limited to, the following:
If you would like more information about our service providers, please contact us using the contact information in the “Contact Us” section below.
Opting out of notifications and push notices
As part of your use of the Apps or website, we may send you email to operate or promote the Apps or other products we believe may be of interest to you. In addition, we may contact you using other personal information that you have provided to us (such as a physical mailing address) or contact information that you have made publicly available (such as through a social networking service). If you no longer want to receive marketing-related emails from us, you may opt-out of receiving marketing-related emails by clicking the “unsubscribe” link at the bottom of any email you receive from us. You may also opt-out by contacting us directly using the contact information in the “Contact Us” section below.
We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request. Please note that if you opt-out from receiving marketing-related emails, we may still need to send you communications about your use of our products or services, or other matters.
With your consent, we may send push notifications or alerts relating to activities on the Mobile App to your mobile device. You can deactivate these messages at any time by changing the notification settings on your or your child’s mobile device.
Retention of personal information
We will use, disclose, or retain your personal information only for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by law.
We have implemented physical, organizational, contractual, and technological security measures to protect your personal information and other information. We have taken steps to ensure that the only personnel who are granted access to your personal information are those with a business ‘need-to-know’ or whose duties reasonably require such information.
While we take precautions against possible breaches in our websites and customer databases, no website, application, or Internet transmission is completely secure, so unfortunately, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Your use of our website(s) and the Apps is at your own risk. We assume no liability for disclosure of your personal information due to transmission errors, unauthorized access, or causes beyond our control, including security failures on the part of our partners and third party service providers and processors.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the “Contact Us” section below.
Rights regarding your personal information
We make reasonable efforts to ensure that your personal information is kept as accurate, complete, and up-to-date as reasonably necessary. We will not routinely update your personal information unless such a process is necessary. We expect you, from time to time, to supply us with updates to your personal information, when required.
Under certain laws you may have the right to write a written request to review any personal information about you that we have collected, used or disclosed, and we will provide you with any such personal information to the extent required by law. You may also challenge the accuracy or completeness of your personal information in our records and request corrections. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend the personal information as required. To exercise these rights, please contact us by using the contact information in the “Contact Us” section below.
You may enquire about your ability to lodge a complaint with the relevant data protection authority.
We may require that you provide sufficient identification to fulfill your request to access or correct your personal information. Any such identifying information will be used only for this purpose.
International transfer and storage of information
Play Roly is based in Canada, and we process and store information in Canada and the United States. As such, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. While such information is outside of your home jurisdiction, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.
However, our practices regarding your personal information will at all times continue to be governed by this Policy.
Our website is not intended for children under the age of 16. Children under the age of 16 should not use our website(s). If you provide us with personal information about a child under the age of consent in connection with use of the Apps, you warrant that you have authorization and authority to provide consent to do so as a parent or legal guardian.
If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16 without the consent of their parent or legal guardian, please contact us using the information “Contact Us” section below.
Any comments, questions, concerns or complaints regarding your personal information or our privacy practices may be sent to our Privacy Officer as follows:
Teaching The Way They Learn Corporation
6209 St. Georges Crescent
West Vancouver, BC
Canada V7W 1Y9
Attention: Privacy Officer
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