Welcome! You have arrived at www.louadventures.com, which is owned and operated by Sparkstone Investments LLC (“Sparkstone”). Throughout this Privacy Policy the words “we”, “us” and “our” refer to Sparkstone, and the words “you” and “your” refer to the user (such as your child or a minor under your guardianship) visiting the www.louadventures.com or the Lou Adventures educational game platform associated with that website (the website and platform are collectively referred to below as the “Platform”). This Privacy Policy applies to information that we collect at the Platform (including any mobile version) and our handling of such information. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of the Platform (unless otherwise stated below). Please review the Platform’s Terms of Use and, if you are a registered user, the User Agreement, which govern your use of the Platform, Sparkstone’s online platform, and any supporting mobile application (the Sparkstone platform and any app, including all related documentation, are referred to herein collectively as the “Application”). 

By accessing and using our Platform and the Application, you consent to our Privacy Policy, our Terms of Use and our collection, use and sharing of your and your child’s information and data, and other activities, as described below. 

1. What Information Does the Platform Collect? 

(a) Information You Provide to Us 

Personal Information. We may ask you, your child or a minor under your guardianship to provide us with, or you might submit via the Platform, personally identifiable information, which is information that identifies an individual personally, such as one’s first and last name, telephone number and e-mail address (“Personal Information”). We may collect this Personal Information through various forms and in various places on the Platform, including account registration forms, “contact us forms”, or when you otherwise upload data to and interact with the Platform. 

  (b) Information Collected or Stored As You Access and Use the Platform 

In addition to any Personal Information or other information that you choose to submit to us via the Platform, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Platform (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Platform. To the extent we associate Usage Information with Personal Information we collect directly from you on the Platform, we will treat it as Personal Information. 

For example, in the Platform, you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year. If you have an account and you log in to use the Platform, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser. When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed. If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day. 

Usage Information may include: 

• your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Platform, and our computers identify your Device by its Device Identifier; 

• your Device functionality (including browser, operating system, hardware, mobile network information); 

• the URL that referred you to our Platform; 

• the areas within our Platform that you visit and your activities there, including remembering you and your preferences; 

• your Device location; 

• your Device characteristics; and 

• certain other Device data, including the time of day, among other information. 
  

Tracking Technologies. We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed): 

Cookies. A cookie is a data file placed on a Device when it is used to visit the Platform. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage. 

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Platform’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Platform, to monitor how users navigate the Platform, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed. 

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Platform, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third-party service provider, is active only while you are connected to the Platform, and is deactivated or deleted thereafter. 

Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification. 

ETag, or Entity Tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies. 

Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices in the same user). 

Tracking Technologies Usage. We may use Tracking Technologies for a variety of purposes, including: 

Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Platform, including cookies required to prevent fraudulent activity and improve security. 

Performance-Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Platform, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Platform. 

Functionality-Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Platform, including identifying you when you sign-in to our Platform or keeping track of our specified preferences, including in terms of the presentation of content on our Platform. 

Targeting-Related. We may use Tracking Technologies to deliver content relevant to your interests on our Platform and third-party sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you. 

Tracking Technologies Choices and Consent. 

We obtain your consent to our information storage or collection Tracking Technologies by providing you with transparent information in our Privacy Policy and providing you with the opportunity to make a choice to disable cookies as set forth above. Please note that we are not required to obtain your consent to the information collection Tracking Technologies identified above that are strictly necessary. 

We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed. 

Third Party Tracking and “Do Not Track.” 

There may be other Tracking Technologies now and later devised and used by us in connection with the Platform. Further, third parties may use Tracking Technologies in connection with our Platform, which may include the collection of information about your online activities over time and across third-party websites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third-party Tracking Technologies in connection with use of our Platform and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties. Also, various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms. 

  (c) Information Third Parties Provide About You 

We may, from time to time, supplement the information we collect directly from you on the Platform with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. To the extent we combine information we receive from those sources with your Personal Information we collect on the Platform, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties, even if they have used our technology to collect it and share it with us. 

  (d) Interactions with Third-Party Platforms 

The Platform may include functionality that allows certain kinds of interactions between the Platform and a third-party website or application. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, when you register with the Platform, you may have an option to use your Facebook, Google or other account provided by a third-party site or application to facilitate the registration and log-in or transaction process on the Platform, or otherwise link accounts. If we offer and you choose to use this functionality to access or use our Platform, the third-party site or application may send Personal Information about you to us. If so, we will then treat it as Personal Information under this Privacy Policy, since we are collecting it as a result of your accessing of and interaction on our Platform. In addition, we may provide third-party sites’ interfaces or links on the Platform to facilitate your sending a communication from the Platform. For example, we may use third parties to facilitate emails, tweets or Facebook postings. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. Sparkstone may not control or have access to your communications through these third parties. Further, when you use third-party websites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on our Platform.] 

2. How Do We Use the Information Collected? 

Generally. We may use your Personal Information or Usage Information that we collect about you: (1) to provide you with information or services or to process transactions that you have requested or agreed to receive; (2) to provide you with information via email about new Sparkstone product or service offerings on an ongoing basis, unless you opt out of receiving such emails; (3) to enable you to participate in a variety of the Platform’s features; (4) to send promotional or marketing emails to you on behalf of the other businesses or organizations; (5) to process your account inquiry, including verifying your information is active and valid; (6) to improve the Platform, to create new service offerings, to customize your experience on the Platform, or to serve you specific content that is most relevant to you; (7) to contact you with regard to your use of any of the Platform and, in our discretion, changes to the Platform and/or any of the Platform’s policies; (8) for internal business purposes; and (9) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy. 

Contact Us. Please note that information submitted to the Platform via a “contact us” or other similar customer inquiry function may not receive a response. 

3. How and When Do We Share Information with Third Parties? 

We will not share Personal Information with third parties for direct marketing purposes. We may, however, share non-Personal Information, such as aggregated user statistics and browsing behavior information, with third parties. We may share the information we have collected, including Personal Information, as disclosed at the time you provide the information and as described below or otherwise in this Privacy Policy. Sparkstone may also disclose Personal Information as follows: 

  (a) Third Parties Providing Platforms on Our Behalf. We may use third-party vendors to perform certain services on behalf of us or the Platform, such as hosting the Platform, designing and/or operating the Platform’s features, tracking the Platform’s activities and analytics, and enabling us to send you special offers or perform other administrative services. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to Personal Information. We are not responsible for those third-party technologies or activities arising out of them, nor are we responsible for the effectiveness of or compliance with any third parties’ opt-out options. 

  (b) To Protect the Rights of Sparkstone and Others. To the fullest extent permitted by applicable law, we may also disclose Personal Information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Sparkstone or third parties (including through the enforcement of this Privacy Policy, our Terms of Use, the User Agreement or other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders). To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you. 

  (c) Affiliates and Business Transfer. We may share Personal Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Platform or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process. 

4. What About Information I Disclose Publicly or to Others? 

User-Generated Content and Public Information. The Platform also permits you to submit ideas, photographs, user profiles, writings, music, video, streamed and recorded audio content, computer graphics, pictures, data, questions, comments, suggestions or other content, including Personal Information (collectively, “User Content”), including as part of your profile. We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you. 

Others may have access to this User Content and may have the ability to share it with third parties. For example, if you upload images to the Platform, you should consider avoiding uploading images with embedded location data (EXIF GPS) included. Other users of the Platform can download and extract any location data from images posted on the Platform. Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Please note that Sparkstone does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available via the Platform or what others do with information you share with them on the Platform. We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the Platform. 

Your User Content is posted and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Content. Therefore, we cannot and do not guarantee that your User Content will not be viewed by unauthorized persons. 

For full terms and conditions regarding User Content you submit to the App, please review the Terms of Use. 

5. Does Third-Party Content or Links To Third-Party Platforms Appear on the Platform? 

The Platform may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Platform are served to you. In addition, when you are on the Platform you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off the Platform onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you or others, including Personal Information, and may or may not have their own published privacy policies. We encourage you to note when you leave our Platform and to review the third-party privacy policies of all third-party websites and exercise caution in connection with them. 

6. How Do I Change My Information and Communications Preferences? 

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The Platform may allow you to review, correct or update Personal Information you have provided through the Platform’s registration forms or otherwise, and you may provide registration updates and changes by contacting us. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information or change your preferences on the Platform, information that you remove may persist internally for Sparkstone’s administrative purposes. You may cancel or modify our e-mail marketing communications you receive from us by following the instructions contained within our promotional e-mails or in some cases by logging into your Platform account and changing your communication preferences. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of e-mails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our Platform, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications. If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways: Postal Mail: Attention: Privacy Officer, Sparkstone, Inc., [physical address]; By e-mail: admin@Sparkstone.com. 

7. What About Transfer of Information to the United States? 

Our Platform is operated in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Platform or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy. 

8. What Should Parents Know About Children? 

We understand the importance of protecting children’s privacy in the interactive world. Please see our Children’s Privacy Policy for more details. California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information. 

9. Your California Privacy Rights 

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit our California Residents Privacy Notice. 

10. What About Security? 

We endeavor to incorporate commercially reasonable safeguards to help protect and secure Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Platform and provide us with your information at your own risk. 

11. What About Changes to the Privacy Policy? 

We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Platform indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable. 

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