Privacy Policy

1. Introduction

GameSchool Ltd (“GameSchool”, “we”, “us”, or “our”) is committed to protecting your

privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your

information when you use our mobile application GameSchool (the “App”) and related

services.

Please read this Privacy Policy carefully. By accessing or using the App, you agree to the

collection, use, and disclosure of your information as described in this policy. If you do not

agree with our policies and practices, please do not use our App.

This policy specifically addresses requirements under the UK General Data Protection

Regulation (UK GDPR), the Data Protection Act 2018, and the Age Appropriate Design

Code.

2. Information We Collect

2.1 Personal Information

We may collect the following types of personal information:

• Account Information: When you register for an account, we collect your name,

email address, age/date of birth, and account credentials.

• Subscription Information: If you purchase a subscription, we collect billing

information and transaction details. Note that payment information is processed by

Apple App Store or Google Play, and we do not directly store your payment card

details.

• Profile Information: Information you provide in your user profile, including optional

information such as profile picture, educational interests, and learning preferences.

• For PRO Tier Users: We create and manage a GameSchool email address on your

behalf to facilitate access to Minecraft: Education Edition.

2.2 Usage Information

• App Interaction Data: Information about how you interact with our App, including

features used, content accessed, time spent on various sections, and learning progress.

• Device Information: Information about your device, including device type, operating

system, unique device identifiers, IP address, and mobile network information.

• Log Data: Server logs, error reports, and performance data related to App usage.

2.3 Information About ChildrenOur App is designed for educational purposes and may be used by children. We take

additional precautions when collecting and processing data from children under 13 years of

age:

• We collect only the minimal amount of personal information necessary to provide our

services.

• We require parental consent before collecting personal information from children

under 13.

• We implement age-appropriate design principles in accordance with the UK Age

Appropriate Design Code.

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 To Provide and Maintain the App

• Create and manage user accounts

• Process subscriptions and facilitate access to services

• Provide access to educational content and custom Minecraft maps

• Create and manage GameSchool email addresses for PRO tier subscribers

• Deliver technical support and respond to user inquiries

3.2 To Improve Our Services

• Understand how users interact with our App

• Identify and fix technical issues

• Develop new features and improve existing functionality

• Analyse learning patterns to enhance educational content

3.3 To Communicate with You

• Send service-related notifications and updates

• Provide information about your subscription

• Respond to your requests and inquiries

• With your consent, send promotional content about new features or educational

resources

3.4 Legal and Security Purposes

• Protect against, identify, and prevent fraud and other illegal activities

• Enforce our Terms and Conditions

• Comply with legal obligations

• Protect the rights, property, or safety of GameSchool, our users, or others

4. Legal Basis for Processing (UK GDPR)

We process your personal information based on the following legal grounds:• Performance of Contract: Processing necessary for the performance of our contract

with you to provide the App and services.

• Legitimate Interests: Processing necessary for our legitimate interests, such as

improving our App, ensuring security, and managing our business.

• Consent: Processing based on your specific consent, such as for marketing

communications or certain types of data collection.

• Legal Obligation: Processing necessary to comply with our legal obligations.

For children under 13, we rely on parental consent as our legal basis for processing personal

information, except where the processing is necessary to protect the vital interests of the child

or another person, or where another legal basis applies.

5. Data Sharing and Disclosure

We may share your information with the following categories of recipients:

5.1 Service Providers

We share information with third-party service providers who perform services on our behalf,

such as:

• Cloud storage providers

• Analytics providers

• Customer support services

• Email service providers

All service providers are contractually bound to use the information only for the purposes of

providing services to us and in accordance with our instructions and this Privacy Policy.

5.2 Microsoft (For PRO Tier Users)

For users subscribed to our PRO tier, we share limited information with Microsoft to provide

access to Minecraft: Education Edition, including:

• Your name

• GameSchool email address

• Subscription status

This sharing is necessary for the performance of our contract with you to provide access to

Minecraft: Education Edition as part of the PRO subscription.

5.3 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests

from public authorities (e.g., a court or government agency).

5.4 Business TransfersIf GameSchool is involved in a merger, acquisition, or sale of all or a portion of its assets,

your information may be transferred as part of that transaction. We will notify you via email

and/or a prominent notice on our App of any change in ownership or uses of your personal

information.

5.5 With Your Consent

We may share your information with other third parties with your explicit consent.

6. Data Retention

We retain your personal information for as long as necessary to provide the services you have

requested, or for other essential purposes such as complying with our legal obligations,

resolving disputes, and enforcing our policies.

If you cancel your subscription, we will:

• Maintain your basic account information if you revert to the BASIC tier

• If you completely delete your account, we will delete your personal information

within 30 days, except for information we are required to retain for legal or legitimate

business purposes

For children’s data, we implement stricter retention policies, keeping data only for as long as

necessary to provide the service and comply with our legal obligations.

7. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal

information:

• Right to Access: Request information about the personal data we hold about you and

how it is used.

• Right to Rectification: Request correction of inaccurate or incomplete information.

• Right to Erasure: Request deletion of your personal information under certain

circumstances.

• Right to Restrict Processing: Request that we restrict the processing of your

personal information.

• Right to Data Portability: Request a copy of your personal information in a

structured, machine-readable format.

• Right to Object: Object to our processing of your personal information.

• Rights Related to Automated Decision-Making: Not be subject to decisions based

solely on automated processing that produce legal effects.

To exercise these rights, please contact us at privacy@gameschool.org. We will respond to

your request within one month. This period may be extended by two further months where

necessary, taking into account the complexity and number of requests.For users in the UK, you also have the right to lodge a complaint with the Information

Commissioner’s Office (ICO) if you believe we have not complied with the requirements of

the UK GDPR or Data Protection Act 2018.

8. Children’s Privacy

Our App is designed to be used by children for educational purposes. We take special

precautions to protect children’s privacy:

• We collect only the minimum amount of personal information necessary to provide

our services.

• We require verifiable parental consent before collecting personal information from

children under 13.

• Parents/guardians of children under 13 can review, delete, or refuse further collection

of their child’s personal information by contacting us at privacy@gameschool.org.

• We do not use children’s personal information for marketing or advertising purposes

without explicit parental consent.

• We design our App with privacy by default, implementing age-appropriate privacy

settings in accordance with the UK Age Appropriate Design Code.

9. Data Security

We implement appropriate technical and organisational measures to protect your personal

information from unauthorised access, alteration, disclosure, or destruction. These measures

include:

• Encryption of personal data

• Regular security assessments

• Access controls and authentication procedures

• Staff training on data protection

• Data breach response procedures

However, please be aware that no method of transmission over the Internet or electronic

storage is 100% secure. While we strive to use commercially acceptable means to protect

your personal information, we cannot guarantee its absolute security.

10. International Data Transfers

Your personal information may be transferred to, and maintained on, computers located

outside of your country or jurisdiction where the data protection laws may differ from those

in your jurisdiction.

If we transfer personal data from the UK to countries outside the UK or European Economic

Area (EEA), we ensure that appropriate safeguards are in place, such as:

• Standard Contractual Clauses approved by the UK or EU Commission

• Binding Corporate Rules

• Transfers to countries deemed to provide adequate protection by the UK or EU11. Cookies and Similar Technologies

Our App may use cookies and similar technologies to enhance your experience, improve our

services, and for analytics purposes. You can control the use of cookies at the individual

browser level, but if you choose to disable cookies, it may limit your use of certain features

or functions of our App.

12. Third-Party Links and Services

Our App may contain links to third-party websites or services, including Minecraft and

Minecraft: Education Edition. This Privacy Policy does not apply to such third-party services,

and we are not responsible for their content, privacy policies, or practices. We encourage you

to read the privacy policies of these third parties.

13. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by

posting the new Privacy Policy on this page and updating the “Last Updated” date at the top

of this policy.

We will provide more prominent notice of material changes, such as by sending an email

notification or displaying a notice within the App. We encourage you to review this Privacy

Policy periodically for any changes.

14. Contact Us

If you have any questions about this Privacy Policy, please contact us at:

GameSchool Ltd

Email: privacy@gameschool.org

Data Protection Officer

Email: privacy@gameschool.org