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Privacy Policy

1. General

This Privacy Policy (“Privacy Policy”) describes the data Boggl Inc. (“Struggly”, “we”, “us” or “our”) collects, how we use that data, and your rights and obligations.

By using or accessing the Service, you agree to the terms of this Privacy Policy. Capitalized terms not defined here have the meanings set forth in our Terms and Conditions (the “Terms and Conditions”), including limitations on damages and the application of Texas law.

We may update our Privacy Policy to reflect changes to our information practices. If we do this and the changes are material, we will post a notice that we have made changes to this Privacy Policy on the Website. Any revisions to this Privacy Policy will become effective the first time you access or use the Service after such changes.

BY SUBMITTING YOUR PERSONAL INFORMATION TO US, YOU ARE CONSENTING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION IN THE UNITED STATES AND TO OUR USE OF YOUR PERSONAL INFORMATION AND ANY RELATED INFORMATION IN THE MANNER DESCRIBED IN THIS PRIVACY POLICY, INCLUDING THE TRANSMISSION TO, AND STORAGE AND PROCESSING OF YOUR PERSONAL INFORMATION BY THIRD PARTIES OUTSIDE THE UNITED STATES. IF YOU ARE SUBMITTING PERSONAL INFORMATION OF THIRD PARTIES TO US, INCLUDING CHILDREN UNDER YOUR CARE OR SUPERVISION, YOU WARRANT AND REPRESENT YOU HAVE THE RIGHT TO PROVIDE THEIR PERSONAL INFORMATION TO US AND YOU WILL INDEMNIFY US AND HOLD US HARMLESS FROM AND AGAINST CLAIMS BY SUCH INDIVIDUALS RELATING TO OUR PROCESSING AND USE OF SUCH PERSONAL INFORMATION WITHIN THE TERMS OF THIS PRIVACY POLICY.

If you do not agree to these Terms and Conditions and the Privacy Policy, you must immediately discontinue use of the Service.

2. Information we collect

a. General Usage Information

When using the Service, we collect your browser type and your IP address (a unique address that identifies your computer on the Internet) and if using the Service through a mobile device, we also collect your device type, and device ID.

b. Account Information

We collect information you enter when creating an account, such as your email address, name, PIN, and settings in your account. We also collect subscription status data, such as the information about last payment date, next billing date, current subscription status, and other information necessary to maintain billing records.

c. Information About Your Child’s Use of the Service

We collect data about Your child’s use of the Service including played and completed tasks, achievements, as well as demographic information that You provide such as name and birthday.

d. Product Feedback

We may contact you to participate in product research activities. These may include surveys, interviews, and other types of feedback sessions. When you participate in these research activities, the information you provide will be used to test, improve, and develop our products.

3. Cookies

The Service utilizes "cookies," which are text files placed on your computer that the Service may use to store data on your computer or send data to our web server. We may use cookie data to "recognize" you when you visit the Service in the future, to troubleshoot how the Service operates, and for internal analysis of how people use the Service. Should you decide not to accept cookies, you may limit the functionality we can provide through the Service. We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of the Service.

you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature; however, you should note that cookies may be necessary to provide you certain features available through the Service.

4. Information Obtained by Third Parties

We use Google Analytics which is a web analytics tool that helps us understand how users engage with the Service. Google Analytics uses first-party cookies to track user interactions as in our case, where they are used to collect information about how users use our Service. This information is used to compile reports and to help us improve our Service. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit https://tools.google.com/dlpage/gaoptout.

5. Use of information obtained by Struggly

Struggly may occasionally send you service related and product change announcements through the general operation of the Service. We will send you reminder notifications to support the Struggly teaching methodology by reinforcing the learning cadence and help maintain your learning streak. We process your data to help provide you with the Service and offer personalized features, to understand and improve our Service and to keep our Service safe and secure.

Struggly may use or share anonymous data collected through the Service, including Activity Data without limitation. As a business, it is critical that we perform our contract with you with the best service possible, and it is in our legitimate interests to perform these processing functions and to enable service emails by default to keep your data secure and provide our Service. You may opt out of any non-essential service emails at any time.

We may also use your contact information to send you notifications regarding new services, offers and promotions offered by Struggly if you affirmatively consent to receive such communications.

Struggly uses this information to provide you with support, to send you essential notifications, to enforce our terms, conditions and policies, to communicate with you, to administer the Services, and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes. Struggly’s Terms and Conditions provide the contractual lawful basis for these processing activities.

6. Third-party Service Providers

Struggly shares personal data with third-party service providers that are essential to our offering the Service to You. We provide personal data to SuperTokens & Auth0 (identity management and authentication), DigitalOcean (hosting and infrastructure), Google (analytics and data services), Logtail (security), and Paddle (payment processing), as these third-party services are needed for the functioning, improvement, and maintenance of the Service.

We will be required to access and disclose personal data in response to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. Additionally, we will access and share account or other personal data when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Service or using the Struggly name, or to prevent imminent harm. This will include accessing and sharing personal data with other companies, lawyers, agents, or government agencies.

Struggly will share aggregate or anonymous data collected through the Service, including Activity Data, for purposes such as understanding or improving the service.

7. Third-Party Websites

The Service may contain links to other websites. We are not responsible for the privacy practices of other websites. We encourage users to be aware when they leave the Service to read the privacy statements of other websites that collect personally identifiable information. This Privacy Policy applies only to information collected through the Service. Struggly’s inclusion of such links does not imply any endorsement of the content on such sites or of their owners or operators except as disclosed on the Services. Any information submitted by you directly to these third-parties is subject to that third-party’s privacy policy.

Please note that you may have cookies placed on your computer by third-party websites that refer you to our Service. Although we do not share your personal data with these third-party websites unless it is reasonably necessary to offer the Service, they may be able to link certain non-personally identifiable information we transfer to them with personal data they previously collected from you. Please review the privacy policies of each website you visit to better understand their privacy practices. In addition, Struggly would like to inform you that anytime you click on links which take you to third-party websites, you will be subject to the third-parties’ privacy policies.

8. Data Subject Rights

Struggly aims to protect Your rights in relation to personal data we hold about you, as required by applicable laws, which may include the following:

  • To request access to, or erasure of, the personal data we hold about you.
  • To request us to restrict the processing of the personal data we hold about you.
  • To object to us processing personal data relating to you.
  • Where you have given us consent to process your personal data, you have the right to withdraw that consent at any time.
  • To export the personal data you have provided to Struggly in a format that can be transferred electronically to a third-party.
  • To delete your account with Struggly by following the instructions available through the Service.

We will retain personal information for the length of time necessary to fulfill the purposes for which we collected the personal information or to demonstrate we have fulfilled our duties or obligations, or retention periods required by applicable law or in which claims may be made or the existence of legal proceedings.

Please note that some of these rights are not absolute. In some cases, we may refuse a request to exercise particular rights if complying with it meant that we are no longer able to meet our contractual obligation to provide you with particular products and services. We will keep you informed as to the actions that we can take when you make your request.

9. California Data Privacy Rights

Residents of California and other jurisdictions may have the right to:

  • Know what personal information we collect about you
  • Access a copy of your personal information
  • Ask how we process your personal information and how it may be shared.
  • Opt out of sharing Your information with certain third-parties.
  • Request that we delete your account and personal information

To make a request relating to these rights, please send an email to [email protected]

10. Children’s Online Privacy Protection Act

Struggly collects personal information from children under the age of 13 only as needed for the operations of the Service and subject to the supervision and consent of their parent or legal guardian. If you believe that we have improperly collected personal information from or about children, please contact us at [email protected] and we will take the appropriate actions.

11. Information security

We have implemented administrative and technical safeguards appropriate to protect the confidentiality, integrity, and availability of your personal data. While we strive to protect your personal information, we cannot guarantee the security of any information you transmit to or from the Service, by email or otherwise, and you provide such information at your own risk. You acknowledge that: (a) there are security and privacy limitations in computer systems and on the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through the Service, including personal information, cannot be guaranteed; and (c) any such information and data may be viewed or tampered with by a third-party while such information or data is being used, transmitted, processed, or stored.

12. Do Not Track

Some web browsers have a “Do Not Track” feature. When logged in, the Service requires tracking certain actions within the Service in order to function properly and will not respond to Do Not Track signals from your browser.

13. Reservation of Rights By Struggly

We reserve the right to limit or deny any data request to the extent permitted by applicable law if: a) acting on the request may be a threat to the personal safety, property, or rights of any other person or organization; b) acting on the request would violate applicable laws or regulations; c) if we do not have sufficient information to verify Your identity. Even after a request, we may also keep personal information where necessary to comply with applicable laws or where necessary to protect a legal right or fulfill a legal obligation.

14. Contact us

For all data privacy inquiries and any questions or concerns you have about this Privacy Policy, you can contact us at:

  • By US Mail: Boggl Inc. 539 W. Commerce Street, Suite 1010 Dallas, TX 75208
  • By email at: [email protected]

If you send us an email requesting that we act regarding your personal information or the right to be forgotten, the requesting email must come from the email address we have on file for you or provide sufficient information that we can verify your identity. All other requests must be verifiable as originating from you or your authorized representative. In order to protect your information, we will only provide or delete personal information where we can reasonably identify the identity of the requestor. We may ask you for additional information to verify your identity.

Last revised on February 14, 2023