Dear Agent,

Alterea Inc. (“Alterea”) is committed to the privacy and protection of your information. This Privacy Policy (“Policy”) covers users of the Agents of Influence game, and addresses the practices we use to safeguard the information you provide to the Agents of Influence game, whether playing online through our website or on an installed application (collectively, “The Game”). Please read this Policy carefully as we wish to help you better understand our practices and feel safe in using Agents of Influence. When you access The Game, you consent to the collection, use and disclosure of your information in accordance with this Policy.

In short, The Game:

• Uses encryption for user logins
• Collects minimal PII from teacher and administrator users
• Processes no Personally-Identifiable Information (PII) from student users
• Collects minimal gameplay information to better understand effectiveness of The Game (collectively, “Gameplay Data”)
• Does not offer “in-app” purchases or sell anything else to students
• Deletes all student accounts and data annually
• Does not sell the information of any user or distribute Gameplay Data for any commercial purposes
• Complies with COPPA

The rest of the Policy covers the following information in further detail:

• What Student information we collect and how that information is used
• What information we collect from Teachers/Educators and Admin users and how that information is used
• What non-personal information is collected from all users and how Alterea uses cookies
• Compliance with COPPA
• State-specific compliance
• Third-party vendors and links to other websites
• Things we do/will do to protect your information
• Right to update
• Contact

What student information we collect and how that information is used

Students, or those playing The Game in middle- or high-school classrooms (collectively, “Students”), will have school accounts (“School Account”), which may be applied once or multiple times to specific classrooms at the school, becoming classroom accounts (“Classroom Account”). Students will be registered by teachers or admins, and will log in using Google or other email addresses, and a username which should be different from their full legal name for the sake of privacy.

As part of The Game, students may be asked to respond to discussion prompts and/or short surveys seeking to improve the quality of the game. These are optional, and students will never be asked to provide PII, and should be instructed not to do so in answering any open-ended questions.

What information we collect from Teachers/Educators and Admin users and how that information is used

Teacher Accounts may be used by school teachers or librarians, as well as educators/student leaders administering the game in other relevant use cases including after school programs and summer camps (collectively, “Teacher Accounts”). Like Student Accounts, Teacher Accounts will use encrypted third-party sign-on through Google or another email address. Additionally, Alterea collects minimal PII from Teacher Accounts, including teacher first and last name, email address, subject(s) and grade(s) taught, school, and class size(s). This data is required for providing licenses of The Game to educators in schools, and allows Teacher Accounts to administer The Game to Student Accounts, preserving Student Account anonymity. This PII is encrypted when used, and is not given or sold to any third parties for commercial purposes.

Admin accounts (“Admin Accounts”) can be used to monitor and organize all Teacher Accounts (and therefore all Student Accounts) at a school or similar institution using The Game, and are subject to similar disclosure of minimal PII: first and last name, email address, and role at school or institution.

In general, we make explicitly clear how your data will be used, and give you the option to accept or reject that. Purposes of data use include sending you emails if you signed up for our mail list, establishing a line of communication for support with or feedback on The Game, sending you important information regarding function of The Game or changes/updates to our Data Security and Policy, to comply with legal processes, to enforce our terms of use, to protect our rights, privacy, safety, or property and that of others, and to pursue available remedies or limit damages we may sustain, or for business purposes of improving this product and/or future products.

What non-personal information is collected from all users and how Alterea uses cookies

What are cookies?

Cookies are bits of text that are placed on your computer’s hard drive when you visit certain websites. We use third-party cookies set by our service provider, Google Analytics, to collect information about how you use The Game, including how long you spend on each page and how you got to The Game. We do not use data collected by cookies to identify who you are.

What non-personal information does Alterea collect?

The Game collects minimal Gameplay Data for each player account. This includes responses to dialogue prompts, time spent playing, performance in mini-games, in-game achievements and items unlocked, and responses to optional surveys seeking to improve the quality of the game. This serves multiple functions:

• Allows for specific and immediate feedback to the player based on decisions they make and performance
• Allows teachers/educators administering the game to students to track the progress and performance of students
• Allows for non-linear (starting in the middle of a module), multi-use (preserving progress over multiple play sessions), and multi-context gameplay (playing on the same account in different classrooms)

Alterea uses cookies in a limited capacity (cookies “expire” at the end of your user session). Stored player information is annually purged by Alterea.

Compliance with COPPA

Alterea complies with the Children’s Online Privacy Protection Act (“COPPA”). COPPA requires that website operators never knowingly collect personally identifiable information (PII) from anyone under the age of 13 without prior verifiable parental consent. Alterea offers access to The Game to children under the age of 13 with the knowledge that it does not ask for or require PII from them. Additionally, Alterea does so under the presumption that you, or any other party facilitating access to The Game, instruct students not to provide any PII in any open-ended questions they encounter.

State-specific compliance

California Consumer Privacy Act (“the CCPA”)

In compliance with the CCPA, Alterea complies with your right to ask us to disclose which, if any, PII we have about you, what we do with it, and to delete it and not sell it. This Policy serves as notification of which types of PII we collect and what we do with it.

New York EdLaw 2-D (“Ed 2D”)

In compliance with Ed 2D, Alterea provides this Policy, and uses third-party encryption technology (Google) to protect personally-identifiable login information.

Third-party vendors and links to other websites

Alterea may collaborate with third-party vendors to offer supplemental educational content furthering the learning objectives of The Game. While we will do our best to vet partners, Alterea is not responsible for the privacy policies or the content of websites to which we link — whether those of third-party vendors or any other website linked — and has no control over the use or protection of information provided by you or collected by those third-party websites. Whenever you elect to access a linked website, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third party and you should familiarize yourself with that party’s privacy policy.

We work with a number of companies and organizations to provide the services of The Game, including hosting and data storage, analytics, communication, game and website development, and impact research. We will never sell your information to these or any other organizations. To protect your privacy we require our vendors to maintain confidentiality of any information and do not authorize our vendors to retain, disclose, or share any information. Alterea uses the following third-party services:

• Firebase: Alterea uses Firebase for hosting data storage
• Bluehost: Alterea uses Bluehost for domain and web hosting
• Google Analytics: Alterea uses Google Analytics for web analytics, as described above
• Google : Alterea uses Google for secure, encrypted sign-on to The Game
• Stripe: Alterea uses Stripe as a third party secure payment system for users to buy the game

Disclosure Exceptions: Notwithstanding the above policies, we reserve the right to disclose your personal information to appropriate third parties if we are required to do so by law or we believe that such action is necessary:

• To comply with legal process such as a search warrant, subpoena or court order;
• To protect Alterea’s rights or defend against legal claims;
• To protect any other party’s rights, property and safety;
• To report to any law enforcement agency any activities that we, in good faith, believe to be unlawful;
• To investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving harassment, abusive messages or potential threats to the physical safety of any person
• In the event that Alterea or all or part of its assets are acquired or transferred to a third party, including in connection with a sale, bankruptcy, or similar event resulting in a change in control, provided that the new owner has agreed to comply with the strict data privacy standards described in this Policy.

Things we do/will do to protect your information

The PII provided by Teacher and Admin Accounts is stored in a secure location, accessible only by two-factor authentication accounts and only by employees who need to access it and are properly trained. Alterea runs periodic penetration tests to check for system vulnerabilities, deletes all student accounts on an annual basis, monitors for suspicious log-in attempts, and encrypts user data whenever possible.

However, “perfect security” is not possible. While we strive to protect the confidentiality of your information, we cannot guarantee the security of any information you provide to us and you do so at your own risk.

Right to update

Alterea may modify this Policy from time to time. We encourage you to review the Policy regularly for any changes. Whenever we change how we use your information or reduce your rights under this Policy, we will provide notice and require your consent to the changes.

Contact

If you have any questions or concerns about this Data Security and Privacy Policy, would like to review, update, or delete and information you have provided us, or have concerns or complaints about our compliance with COPPA, please email us at thealterea@gmail.com

Misc.

Our privacy policy is effective as of February 12, 2023.

You agree that your use of this Privacy Policy and any disputes relating thereto shall be governed in all respects by the laws of the State of California. Any dispute relating to this Privacy Policy shall be resolved solely in the state or federal courts located in Los Angeles, California.