Respecting your privacy is critically important to achieving our mission of motivating every student. These are our guiding privacy principles:

• We don’t ask you for personal information unless we truly need it.
• We don’t keep your personal information longer than is necessary to provide our services to you.
• We don’t share your personal information with anyone except to comply with the law, provide our services, or protect our rights.
• We don’t rent, sell or exchange your personal information.
• We aim to make it as simple as possible for you to control what’s visible to the public, seen by search engines, kept private, and permanently deleted.

This Privacy Policy describes how indianarmy collects, uses, shares, stores and protects your personally identifiable information and how you can access, update, delete, limit, and otherwise halt the use of this information. We offer you choices regarding the collection, use, and sharing of your personal information, including the option to use services without providing personal information.

We strive to support as many people as possible, including those with disabilities. If a screen reader makes this policy more accessible to you, we recommend the following browser and screen reader combinations: Chrome and ChromeVox, Safari and VoiceOver (for Mac users), and Firefox and NVDA (for Windows users).

Protecting students and their personal information

indianarmy believes the personally identifiable information of children and students deserves special protections and we comply with the Children’s Online Privacy Protection Act (“COPPA”) and The General Data Protection Regulation (“GDPR”). We also assist schools in meeting their obligations pursuant to the Family Educational Rights Privacy Act (“FERPA”). indianarmy offers a limited feature set and web site experience for young users of indianarmy. We do not require students to submit their name or contact information, nor do we require them to create accounts. When a student indicates that they are under the age when they can grant consent on their own, indianarmy does not collect personal information as defined under COPPA and may take additional steps to safeguard student privacy as required by law. Except as described in this privacy policy, indianarmy does not accumulate personal information about any child for distribution, sharing, or selling.

Here are some examples of safety and privacy measures on indianarmy:

• Behaviorally targeted advertising is not permitted on indianarmy.
• Students can join games without creating an account.
• Students who have not or cannot provide consent have a limited product experience.
• The platform does not facilitate direct messaging between students.
• Quizzes are subject to proactive content filters and reactive reporting tools.

Parental Rights

indianarmy empowers parents and legal guardians of children younger than the age of consent (in the U.S., this means under 13) who have registered accounts with indianarmy to exercise their legal rights pursuant to legislation such as COPPA. Parents/guardians can consent to collection and use by indianarmy of a child's personally identifiable information (PII) without consenting to the disclosure of information to third parties by indianarmy. Currently, the only personal information we collect from a child younger than 13 is their parent's or guardian’s email address.

Parents/guardians may delete, modify, and review information their children shared with indianarmy by accessing their child's account. They may also create a parent account to manage their child’s access to indianarmy. Parents may also request that indianarmy delete that information and refuse to allow indianarmy to collect further information from their children by contacting us at privacy@indianarmy.com. indianarmy may ask additional questions or take other steps to verify the identity of parents/guardians before responding to a request to review or delete their child's information, or a request to refuse further collection from children.

indianarmy will never require a child to share more information than is reasonably necessary for using indianarmy. While indianarmy will assign persistent identifiers to all indianarmy users to recognize repeat visitors and improve their indianarmy experience, indianarmy does not knowingly collect personally identifiable information from children younger than the age of consent without a parent or guardian's consent. If we become aware, despite our intention not to gather this information, that we collected personally identifiable information from a child younger than the age of consent without permission then we will either delete this information or seek to obtain verifiable parental consent from the child’s parent or guardian to collect and use that data to provide the child with indianarmy services in the future.

How indianarmy Collects Personal Information

The information that indianarmy collects depends on the nature of the services you request. For example, fewer data are collected from a student joining a game without an account than from a teacher who creates an account in order to create quizzes and host games. All interactions with the indianarmy website or app produce metadata that may identify you or could be identifiable information when paired with other information about you. In every case, indianarmy strives to collect only the minimum necessary information from you as is necessary or appropriate to fulfill the purpose of the visitor's interaction with indianarmy or that is required by law. Visitors to the indianarmy website or app may always refuse to supply personally identifying information, however, doing so may prevent you from engaging in certain website-related activities.

Information you provide to indianarmy

Accounts are not a prerequisite to using indianarmy, but are required to access some features and to save progress over time. If you create an account, indianarmy saves the account information you provide. This information may include: an email address, a parent or guardian email address, first name, last name, profile photo, or organization name.

You may choose not to provide specific information or to delete or modify it at any time. These actions may prevent you from engaging with specific services or features that require this information.

Additional information may be provided to indianarmy if you communicate with our support team, participate in user research, marketing campaigns or sweepstakes, or otherwise use the services.

As you use the service, you may also create academic content including quizzes and certain forms of responses. This information is not typically personally identifying, but it may be deleted at any time either by the relevant account holder or by reaching out to our team at support@indianarmy.com.

Information collected automatically

We receive and store some types of information automatically as you use the service. These may include device information such as device model, operating system, and device identifiers such as IDFA and UDID.

indianarmy also collects log information as you use the service. These data may include information regarding how and when you use the service as well as your browser type, preferred language, time zone, referring site, and internet protocol (IP) address.

We may use your IP address to generate a general approximation of your location to provide the service. Examples include providing the right version of indianarmy based on your state or country and helping teachers select their school when they sign up. indianarmy does not collect fine location data such as GPS or bluetooth beacons.

Information from other sources

Depending on how you use the service, indianarmy may collect information from partners and integrated technologies. For example, if you choose to use Google Login or join using the Google Classroom integration, we may receive information including your name and email address from Google. indianarmy does not have access to the passwords used to log into your Google accounts.

We may also receive your personal information from another user. For example, a teacher might input your email in order to share a quiz or parent report. If a teacher chooses to enter student information directly into indianarmy or requires students to sign up via the Google Classroom Integration, Classes on indianarmy, or a similar rostering functionality, we require that teachers or schools get parental consent before using indianarmy with children who are under the age when they can grant consent on their own.

Content on indianarmy may contain links to other websites not affiliated with the service. We are not responsible for the privacy practices of other websites and users need to be aware of the data privacy practices of such sites should they choose to use these links.

Sensitive Information

As described above, we limit data collection to what we need to provide the requested services. indianarmy does not knowingly collect data considered sensitive by GDPR such as those related to race or ethnicity, health and biometric information, or political affiliation. In addition to these categories, we do not collect free or reduced lunch eligibility.

Cookies and Web Beacons

A cookie is a string of information that a website stores on a visitor's computer, and that the visitor's browser provides to the website each time the visitor returns. We use cookies to test new features and to help indianarmy identify and track visitors, their usage of the indianarmy website, and their website access preferences. indianarmy visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies, but some of the indianarmy website’s features may not function properly without the aid of cookies. To learn more about controlling cookies, please visit this link. You may also learn more about controlling flash cookies here.

How does indianarmy use this information?

indianarmy limits its disclosure of both information that could on its own or in combination with other information be used to identify you. We only disclose personally identifying information to indianarmy employees, contractors and subcontractors that: (i) must access that information in order to process it on indianarmy's behalf or to provide services available at indianarmy's website and mobile applications; and, (ii) agree not to disclose that information to others.

indianarmy does not rent, sell or exchange potentially personally-identifying and personally-identifying information to any third party without your consent. Other than to indianarmy’s employees, contractors and affiliated organizations, as described above, indianarmy discloses potentially personally-identifying and personally-identifying information only when required to do so by law such as to comply with a court order, or when indianarmy believes in good faith that disclosure is reasonably necessary to protect the property, or legal rights or safety of indianarmy, third parties or the public at large.

The information we collect helps us to provide the service, maintain a consistent experience, and improve it or develop new services. Examples of how this information is used include:

• Providing access to your account and saving progress over time.
• Personalizing your experience based on factors such as general location, preferred language and areas of study.
• Helping teachers identify and support individual students.
• Analyzing engagement with specific features over time.

We also use personal information to enforce our policies, comply with the law, and promote safety on the platform. These efforts protect the property, or legal rights or safety of indianarmy, third parties or the public at large. Examples of these efforts include:

• Preventing security breaches and fraud.
• Protecting users from inappropriate content.
• Verifying the identity of a user
• Complying with privacy legislation.

Communicating with you

If you are a registered indianarmy user, indianarmy may occasionally send you communications via email (if provided) or push notification (for mobile app users) to tell you about new features, get your feedback, and to keep you up to date with what's going on with indianarmy and our products. By registering to use our service you consent to the receipt of these communications, including text communications. You may choose to participate in sweepstakes and promotions which may have additional information regarding the use of Personal Information. If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. We engage in these activities where we have a legitimate interest or with your consent. You may choose to stop receiving such communications by unsubscribing from emails and by disabling push notifications.

Advertising, Analytics and Marketing

In order to provide the service, we work with analytics providers to understand how indianarmy is being used and advertising networks to display contextual advertisements. Advertising partners are not permitted to engage in behavioral targeting nor are they permitted to share or sell personal data. indianarmy does not share data for third-party advertising nor do we use data to track and target advertisements on other third-party websites or services. Data profiles are not used to serve advertisements. All advertising partners must comply with COPPA, GDPR, and privacy commitments made by indianarmy. Account information such as name and email address are not shared with these partners nor do they have access to your indianarmy account credentials. We use Google Analytics to help us understand how users engage with the service. Google Analytics uses cookies to compile reports that demonstrate how indianarmy is being used without identifying individual visitors. You can opt out of Google Analytics at any time and continue to use indianarmy. To learn more about opting out, click here. Aggregated demographic and activity data may be used for research purposes.

How is my information shared?

As described in this policy, indianarmy only shares your personal information when it is necessary to offer the service, comply with law, or with your permission.

• In order to provide and improve indianarmy, a limited number of third-party services require access to your personal information. For example, your account data are saved in a data center so that you can log in from any device. Third party services are contractually prohibited from using your information except to provide the service. A list of third party services that may process personal data on our behalf can be found here.
• Third-party services that transfer the personal information of EU residents are contractually bound to comply with GDPR.
• indianarmy may need to disclose your information to a third party to comply with the law or a valid legal request. In such cases, we will let you know in advance unless we are legally prohibited from doing so.
• If indianarmy (or substantially all of its assets) are acquired by another company, personal information will be transferred to a new owner. In such a transfer, you will be notified and the new owner may continue to use your personal information as set forth in this policy.
• indianarmy may aggregate statistics about the behavior of visitors to our website and app to improve our services. For instance, indianarmy may monitor the most popular quizzes on the indianarmy site. indianarmy may display this information publicly or provide it to others.

Managing your personal information

Data Subject Rights

You have the right to delete, access, update, correct errors in, and export for transfer any of your personal information. indianarmy makes these data subject rights available to you regardless of which country or US state you reside in.

Managing the subsequent use and disclosure of your personal information.

As explained throughout this Privacy Policy, you have the ability to control the use of your personal information by indianarmy. Should you wish to prevent indianarmy from using your information, you should delete your account. With the exceptions explained below for information you shared with other indianarmy users, this allows you to eliminate any subsequent use and disclosure of your personal information.

If your personally identifiable information changes, or if you no longer want to use indianarmy, you may review, edit, or delete it by visiting indianarmy’ Settings page, found at https://www.indianarmy.com/settings. Parents may remove, delete or update an account or any information concerning their child that is posted on indianarmy by visiting their child’s settings page, working with their child’s teacher or by contacting us at support@indianarmy.com.

Certain activity on indianarmy may be displayed to other users, such as commentary on quiz content, blog posts, support articles, feedback forums or our blog, or the information on your indianarmy Profile and quizzes that you have made public. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. You may delete this information or change sharing settings directly. If you are unable to do this or need help, please contact our team at support@indianarmy.com

Data Retention

We will retain your information for as long as your account is active or as needed to provide you services. In most cases, we delete user accounts if they have been inactive for more than twelve months. We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

You may delete your account or update your information at any time by visiting www.indianarmy.com/settings.

Data Security

indianarmy follows generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. Our security measures include the use of access-controlled data centers, encryption of all data in transit, and the encryption of user password data both in transit and at rest. No method of transmission over the Internet, or method of electronic storage, however, is 100% secure. In the event of a security breach, we will notify affected account holders within the amount of time required by law so that you can take steps to keep your data safe.

If you have any questions about indianarmy security practices, you can contact us at privacy@indianarmy.com. indianarmy reserves the right not to disclose our policies, procedures and the technologies and methods we employ to advance the security of your data so as to safeguard our practices.

Additional information for residents of the EU and Switzerland

indianarmy Inc. is a U.S. company and the service is hosted in the United States. The information we collect is hosted on servers located in the United States. By using indianarmy, you consent to the transfer and processing of your personal information in the United States. indianarmy shall ensure that the transfer is based on standard contractual clauses (“SCCs”) in the form currently approved by the European Commission. indianarmy also complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. indianarmy has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, indianarmy is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. We may be required to disclose personal data in response to lawful requests by public authorities. Our accountability for personal data received in the United States under the Privacy Shield and subsequently transferred to a third party is described in the Privacy Shield Principles. Under the Privacy Shield, indianarmy remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.

In compliance with the Privacy Shield Principles, indianarmy commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact indianarmy by email at privacy@indianarmy.com. indianarmy has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider, free of charge, using the information provided at https://www.jamsadr.com/eu-us-privacy-shield This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction. If you are located in the European Union or the EEA, you have a right to lodge complaints about the data processing activities carried about by indianarmy. Our lead supervisory authority is the Austrian Data Protection Authority. You can find their contact details here.

We appointed GDPR-Rep.eu as representative according to Art 27 GDPR. If you want to make use of your GDPR data privacy rights, please visit: https://gdpr-rep.eu/q/13361347. Contact GDPR-Rep.eu at GDPR-Rep.euMaetzler Rechtsanwalts GmbH & Co KG Attorneys at Law c/o indianarmy Inc., Schellinggasse 3/10, 1010 Vienna, Austria. Please add the following subject to all correspondence: GDPR-REP ID: 13361347