Privacy policy.
This Privacy Policy (“Policy”) describes how and when IOU Concepts Inc. (“we” or “IOU”) collects, uses, and shares personally identifiable information (“Personal Information”) when you use its applications, websites and other services (collectively, the “Services”). This Policy does not apply to websites, applications or other services that do not display or link to this Policy, or that have their own privacy policy. By using the Services, you consent to IOU’s collection, transfer, storage, disclosure, and use of your information as set out in this Policy.
IOU Concepts Inc.’s Privacy Policy was developed referencing PIPEDA with a special focus on the handling of data with respect to schools & students.
1. What personal information do we collect?
We collect many kinds of Personal Information to operate effectively and provide you with the best services and user experiences we can. In particular:
Account and Activity Information
We collect many kinds of Personal Information to operate effectively and provide you with the best services and user experiences we can. In particular:
Account creation and optional profile information
To create an account on one of our Impact Gaming platforms, there are different requirements depending on the type of impact game you are managing or participating in.
To launch a private, invitation only impact game as an administrator you must create an account with a validated email address and password.
To launch a private, invitation only impact game as an education based administrator (example: teacher) you must create an account with a validated email address and password.
To participate as a player in a public impact game you must create an account with a validated email address and password.
To participate as a player in a private, invitation only impact game as an education based player (student) you must create an account with only a screen name and password (i.e. no email or other personal details required).
You may choose to update the profile associated with your account by sharing your address, birthday, age, gender, marital status, a photo of yourself, and other optional personal information to personalize and share your social impact profile/resume as well as receive notifications of in-game play and new game launches and related details as well as prize/reward delivery where applicable. We may also collect information about your usage of our Services in association with your account, such as the impact games you view, the challenges in which you participate, the links you click, and your search queries and results.
Website Information
When you access our websites, we automatically collect your computer’s internet protocol (IP) address and other technical information about your computer and website usage, such as your browser type and version, time zone setting, and operating system and platform. We also use cookies on our websites; for more information, please see the Cookie Information section of this Policy below.
Mobile Information
When you use our mobile applications, we collect your device’s unique identifier and other technical information about your device and application usage.
We may also collect Personal Information that allows us to be in contact with you (such as email address, phone number, and address), information about your user experience or opinions, and other Personal Information that you voluntarily provide to us when you contact us with a question or comment about our products and services.
2. How do we use your personal information?
We use your Personal Information to provide and optimize our Services. In particular, we use:
Account and Activity Information to manage your account, identify impact games and challenges that may be of interest to you, calculate your XO score (a measure of the positive impact you are making), communicate with you in relation to your account, personalize our Services for you, provide you with customer service, and monitor the performance of our Services.
Should you participate in a public impact game, your activities in connection with the Services within that public will be public including challenge submissions. Any participation in a private, invitation only impact game will remain private to the invited participants of that impact game.
Website Information and Mobile Information to monitor the performance of our Services, analyze trends, usage and activities in connection with our Services, and ensure their technological compatibility with users.
We also use the Personal Information you provide us to respond to your comments and questions, better understand your needs, and generally improve and enhance our products and services.
We may wish to use your Personal Information to provide you with marketing communications promoting our products and services, or those of third parties. We will only do so with your consent and as permitted by law. We will not use Personal Information for any purpose incompatible with those outlined in this Policy.
3. What personal information do we disclose?
We do not sell or rent your Personal Information to others. If you create an account on our Services, we create a profile that displays your full name (optional if student) and photo (optional), as well as your achievements and activities in connection with the Services. Your profile is private and is not available to anyone on or off our Services unless you choose to make it public. If you participate in an impact game by submitting a challenge, we post the content you added to evidence completion of the challenge which may include username, team, photo, video, and text related to the challenge itself and depending on the access level of the game (invitation only or public) challenge submission content may be posted on a publicly accessible portion of the Services.
Apart from the above, we only share Personal Information with third parties who are bound by terms at least as restrictive as this Policy and only in the following ways:
Affiliates
We may share Personal Information with any of our subsidiaries, or our ultimate holding company and its subsidiaries, for the purpose of providing our Services and improving our products and services.
Service Providers
We may share Personal Information with third-party service providers who perform a variety of functions to enable us to provide our Services, such as hosting our Services, and analyzing and improving our Services. These service providers only have access to the Personal Information necessary to perform their functions, only act on our behalf and under our instructions, and may not use it for purposes other than to perform such functions.
Current service providers and links to their privacy policies:
Web hosting: Digital Ocean https://www.digitalocean.com/legal/privacy-policy
Newsletter: Survey Monkey www.surveymonkey.com/mp/legal/privacy
Legal
We may disclose Personal Information to courts, law enforcement agencies, and other government bodies if we suspect that an individual’s use of our Services involves illegal activity or is otherwise inconsistent with any applicable terms and conditions. We may also disclose Personal Information where we believe that doing so would be in accordance with or required by any applicable law, regulation or legal process.
Business Transfers
In the event of a reorganization, merger or sale, we may transfer any and all Personal Information we collect to the relevant third party involved in the reorganization, merger or sale, with the consent of data subjects if and as required under applicable privacy laws.
With Your Consent
We may also share Personal Information with other third parties subject to your prior consent.
4. How do we protect your personal information?
We maintain reasonable administrative, technical and physical safeguards to protect Personal Information against loss, theft, misuse and unauthorized access, disclosure, alteration and destruction as required by applicable law. Unfortunately, the transmission of information via the Internet is not completely secure. Despite our safeguards, we cannot guarantee the security of information transmitted to us via the Internet. Once we have received your information, we will use all reasonable safeguards to protect it.
5. Where is your personal information stored?
If you use our Services from outside Canada, please be aware that your Personal Information will be transferred to, stored, and processed in Canada. The data protection laws of Canada may not be considered adequate by authorities in your home country, but please be assured that we take steps to ensure that your Personal Information is collected, processed, protected and transferred in accordance with applicable law.
6. Cookie Information
Cookies are small text files that are stored on your computer when you visit our websites. The use of cookies is a standard practice among websites to collect information about visitors’ activities while using the website. We use cookies to enable our Services to work, confirm whether you have logged into your account, improve your browsing experience, and collect aggregate data about usage of our websites. In particular, if you sign into an account on our websites, we use user ID cookies to verify your identity and preference cookies to remember your personal settings.
To manage the cookies that are placed on your computer, you may configure your internet browser to refuse, accept or delete cookies from our websites at any time. The help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Please note that if cookies are disabled or removed, not all features of our websites will operate as intended.
7. External links
This Policy does not apply to the collection, processing and use of Personal Information by companies that we do not own or control, or to people that we do not employ or manage (“External Parties“). Although some of our Services link to the websites and services of External Parties, such as those of our business partners and social media companies, we do not exercise control over the activities of External Parties. For more information about what Personal Information External Parties collect and how they use such Personal Information, please refer to their privacy policies.
8. Access, corrections and other rights
You may exercise the statutory rights you may have under applicable law, such as to access, correct, update, delete, block or limit our use of your Personal Information (except if you have misused or are suspected to have misused our system), please contact us by the means noted below and clearly describe your request. We will try to comply with your request as soon as reasonably practicable and always under the timeframes set forth by applicable laws. Please note that we may need to retain certain information for certain purposes as required or authorized by law.
If you have any questions about this Policy, please contact our privacy officer at privacy@xocial.com or IOU Concepts Inc., 12 James Street North, Suite 302 Hamilton, ON L8R 2J9 ATN Privacy Officer.
9. Storage and retention of user information
One of the main components of our value proposition is the ability to track the historic positive social impact of an organization or individual over time. Particularly beneficial to students, a Social Impact Games profile provides an extracurricular record (or resume) of social impact activities that can be beneficial, for example, as a supplement to post secondary education applications. As such, we do not actively remove historical data or inactive user accounts as historic impact has value to the users which may be referenced for years after the engagement with the platform has been completed. We do offer the ability to delete your account and at that time the account is deactivated and all historic information is deleted from the platform.
10. In the event of a data breach
In the event of a data breach users will be notified by email and/or phone number if one has been provided in their profile. Notice of data breach will also be posted on the corporate & gaming websites and will contain the nature of the breach, what is being done to mitigate the issue, and when the next update will be posted.
11. How we built & maintain our privacy policy
We reference and comply with PIPEDA in the development of our privacy policy.
12. Revisions to the policy
We may update this Policy from time to time. Any changes will be preceded by a notice posted on the relevant Service. If you disagree with our revisions to the Policy, you may de-activate your account or discontinue the use of our Services.
Updated May 25, 2023.