Privacy Policy

Effective: December 30, 2020

Welcome to Group Lore, LLC. We provide digital programming with interactivity primarily for kids. At Group Lore LLC (“Group”) we operate this website (“Website”) and are committed to protecting the privacy and security of its online visitors—especially the privacy of children who visit this site.

We are sensitive to family concerns about children’s safety and information related to them. We want you to know about and understand the measures we have taken to keep our website and all of our online services provided by Group safe and secure for everyone. We would like every visitor to know that we do not knowingly collect any personally identifiable information from children.

We encourage our visitors to read through and understand our privacy Policy. We may update it from time to time to address new issues or reflect changes on our Website. Please refer to this privacy Policy regularly. Group reserves the right to revise this privacy Policy at any time and such revisions shall be effective immediately upon notice thereof. Notice may be given by any means including, but not limited to, posting the revised privacy Policy on this Website. Any use of our site by you after such notice shall be deemed to constitute acceptance by you of such revision.

If you have any questions or concerns about this privacy Policy, or your dealings with Group, please:

1. Contact us at info@theway-saga.com

2. Write to us at: Group Lore, LLC

We care about data privacy and security.  We never share your data. By using our Website, you agree to be bound by our Privacy Policy posted on the Website. Please be advised the Website is hosted in the United States. If you access our Website from the European Union, Asia, or any other region of the world with laws or other requirements governing personal data collection, use, or disclosure that differ from applicable laws in the United States, then through your continued use of the Site, you are transferring your data to the United States, and you expressly consent to have your data transferred to and processed in the United States. Further, we do not knowingly accept, request, or solicit information from children or knowingly market to children. Therefore, in accordance with the U.S. Children’s Online Privacy Protection Act, if we receive actual knowledge that anyone under the age of 13 has provided personal information to us without the requisite and verifiable parental consent, we will delete that information from our Website as quickly as is reasonably practical.

HELPFUL EXPLANATIONS

An IP address is a number that is assigned automatically to your computer whenever you use the World Wide Web. Web servers — the computers that “serve up” Web pages — automatically identify your computer by its IP address.

Cookies are small pieces of data stored on your device as a text file (computer or mobile device).

Personally identifiable information means information that would identify you, directly or indirectly, such as your name, mailing address, email address or telephone number (“Personal Data”).

Anonymized information means information that does not or could not reasonably be used to identify a specific individual.

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information and anonymized information are, or are to be, processed.

For the purpose of this Privacy Policy, Group is the Data Controller of your Personal Data.

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

 

INFORMATION WE COLLECT FROM YOU

We do not knowingly collect personal information from our visitors though visitors might provide us personal information by reaching out for support or joining our mailing list.

We do collect anonymized information regarding site activity from users.

Our Website may contain games where free form text entry is permitted, but this content is only visible to the person playing the game. Additionally, we utilize this user generated content in conjunction with contests among our users. In no cases, however do we host games that allow children to post or share personal information publicly.

We collect anonymized information from your computer or device such as browser type, operating system, referring pages, pages visited, time spent on a particular page and IP address. IP addresses are automatically anonymized.

HOW WE COLLECT YOUR INFORMATION

When you use our Website, we collect Personal Data and anonymized information through a variety of methods.

We collect Personal Data from you when you interact with our Website by reaching out to submit a customer service requests or sign up for a subscription or membership to our Website, or to join our mailing list.

We collect anonymized information from you by using technologies like cookies, web beacons and server logs.

This Website contains cookies from Group and third parties. While browsing through this Website, you may get cookies from our advertisers or sponsors. Group does not control these cookies.

We may also use single pixels images, web beacons and other similar technology (collectively “Beacons”) to (a) track your usage of our Website, (b) track response rates to certain activities and promotions within the Website and in marketing campaigns, and (c) identify certain information on how and when you accessed the Website such as type of browser, operating system, domain names, IP addresses and the like.

HOW WE USE YOUR INFORMATION

Group may use your personal information to tailor the content programming, services, and applications that we provide to meet your needs and interests.

When our users request pages from our Website, our servers log users’ IP addresses. IP addresses are automatically anonymized. Our users session will be logged, but the visitor remains anonymous to us.

Group collects IP addresses for system administration, to report aggregate information to our advertisers, sponsors, and partners, and to audit the use of our site. We will use IP addresses to identify a user in the following situations: (a) in response to subpoenas, court orders or legal process, to the extent permitted and as restricted by law; (b) when disclosure is required to maintain the security and integrity of this site, or to protect any user’s security or the security of other persons, consistent with applicable laws. The anonymized information we track with cookies is not used to identify, or lead us back to, any particular individual. Visitors to this Website may have the option of disabling cookies via their browser preferences (most browsers are initially set up to accept cookies). Cookies make our Website easier for you to use because they save your preferences while you are visiting our sites (although we do not save passwords in cookies).

Group may also use third party vendors who supply applications, web hosting and other technologies for this Website that may have access to your Personal Data and anonymized information but by mutual agreement will never use such information for any other purpose except to provide services in connection with this site.

Group will not share any Personal Data about you with any third party, except as otherwise stated in this Privacy Policy and in the following circumstances: (a) in response to subpoenas, court orders or legal process, to the extent permitted and as restricted by law; (b) when disclosure is required to maintain the security and integrity of this site, or to protect any user’s security or the security of other persons, consistent with applicable laws; (c) when disclosure is directed or consented to by the registered member who has input his/her Personal Data; (d) in the event that Group goes through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of its assets, your Personal Data will, in most instances, be part of the assets transferred; or (e) in limited circumstances, Group may disclose your email address in order to comply with laws and regulations, including the Controlling the Assault of Non-Solicited Pornography and Marketing Act (CAN-SPAM of 2003).

DO NOT TRACK

This Website does not respond to your browser’s (or app’s) “do-nottrack” signals or comparable signals or mechanisms. Please check our Privacy Policy frequently as this may change in the future.

CHILDREN’S PRIVACY

Group strongly encourages parents and guardians to supervise their child’s use of the Internet. We urge parents to instruct their children to never give out their real names, addresses, phone numbers, or other Personal Data without a parent’s or guardian’s permission when using the Internet. We recognize a special obligation to protect personal information obtained from children and by design do not collect this information. For this reason, Group does not request, collect, or store any personal information knowingly from children under 18. Some games might ask children for their names, but this information is never shown to us and is only seen locally on the child’s machine.

In compliance with COPPA (the Children’s Online Privacy Protection Act), we have adopted the following policies to keep kids safe (there are exceptions to these policies as noted below under the heading “Exceptions to Verifiable Parental Consent and Information Collected from Children”):

• We will NOT knowingly collect, use, or distribute personal information from children under the age of 18 without prior verifiable consent from a parent or guardian.

• We will NOT knowingly ask a child under the age of 18 to divulge more information than is needed to participate in any activity, game, or service.

• We will NOT knowingly keep any Personal Data that is inadvertently included in a child’s email submission, help inquiry, or other one-time request, if we know that the child is under the age of 18. Any such information will be purged promptly after the issue has been resolved.

• We will NOT knowingly post any personal information that is inadvertently included in a child’s submission to a general audience contribution area if we know that the child is under the age of 18. Upon notice to us, these submissions will be deleted and handled anonymously thereafter.

• We will NOT knowingly provide any direct link to websites that are unsuitable for children or teens.

• Upon request, Group will provide a parent or guardian with a description of the information that may have been provided about their child during a registration process for a program or to access any of the services of our website. Group only asks for a child’s or teen’s personal information if it is necessary to participate in an activity, game or service. If we have collected and stored personal information from a child, we will give parents the ability to review their child’s personal information, request that we discontinue further collection or use of their child’s personal information, and/or request that we delete their child’s personal information.

If you have any questions about this Privacy Policy, please contact Group at info@theway-saga.com

NOTIFICATION AND VERIFIABLE PARENTAL CONSENT

Before any personal information is collected from a child, we will do our best to notify the parent or guardian that their child is participating. Notification will include the exact nature and intended use of the information we are collecting, as well as the opportunity for the parent or guardian to prevent the use of the information and the child’s participation in the activity. For every child (anyone under 18 years of age), we will also require the parent or guardian to provide verifiable parental consent such as: by email plus a fax, phone or letter follow up by the parent or guardian; mail, fax or scan of a consent form; or tollfree phone call to Group; or other acceptable method.

In order for us to provide notice to a parent or guardian and seek verifiable parental consent, we may request the online contact information of a parent or guardian. This contact information will only be used for the sole purpose of obtaining verifiable parental consent or providing notification to the parent or guardian.

GAMES AND CONTESTS:

We will never condition a child’s participation in a game, the offering of a prize, or another activity on the child disclosing more personal information than is reasonably necessary to participate in such activity.

ABOUT OUR ADVERTISERS

This Website may include advertising by third parties from time to time. Group does not control the linking practices of advertisers or sponsors and does not monitor or claim responsibility for any content or privacy practices of such websites. Once you have clicked on an advertisement and have left our Website, you must read the privacy policy of the advertiser or sponsor to see how your personal information will be handled.

Group may offer contests, sweepstakes, and promotions that are sponsored by third-party advertisers or sponsors. These third parties may obtain Personal Data that visitors voluntarily submit to participate in the activity. Group does not control the third parties’ use of information.

Group may use advertising servers developed by third parties to display ads on our Website. Some of these ads may contain cookies that are set by third parties (advertisers, sponsors) and may use anonymized information (not including your name, address, email address, telephone number) about your visits to this and other sites in order to provide advertisements about goods and services of interest to you. We do not have access to these cookies or any information that they transmit. The Group Privacy Policy does not cover any use of information that a third-party ad server may have collected from you. Please note that Group does not engage in the practice of showing or tracking users for interest-based advertisements on its child-directed sites. Group’s advertisers have all agreed to only show ads appropriate for children.

For more information on ad serving, please contact us at: info@theway-saga.

A NOTICE ABOUT EXTERNAL LINKS

Occasionally, you will find links from Group to independently owned, controlled, and/or managed Websites whose content we believe will be of possible interest and value to our members and/or visitors. Additionally, you’ll see links from advertisers, sponsors, and other partners who may use a Group owned logo as part of a co-branding agreement.

In many cases, these links represent cooperative projects or mutual links established with the organizations connected with these sites. We do not control the content of these links.

Group has partnered with other companies to provide certain services. In some cases, you may see a Group logo on another company’s site. Group does not share any of your personal information with these partners and they do not share any information with us.

We specifically recommend that children check with their parents, guardians, or teachers before connecting to any third-party sites.

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Group legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Group may process your Personal Data because:

• We need to perform services in conjunction with a contract with you

• You have given us permission to do so

• The processing is in our legitimate interests and it’s not overridden by your rights

• To comply with the law

Retention of Data

Group will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Group will also retain data surrounding your usage of our Website for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website or its services, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Group will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure Of Data:

Disclosure for Law Enforcement

Under certain circumstances, Group may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Legal Requirements

Group may disclose your Personal Data in the good faith belief that such action is necessary to:

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

“Do Not Track” Signals

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Group aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or to delete the information we have about you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

You have the right to have your information amended, modified or otherwise changed if that information is inaccurate or incomplete.

You have the right to object and therefore to stop to our processing of your Personal Data.

You have the right to request that we restrict the processing of your Personal Data.

You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.

You also have the right to withdraw your consent at any time where Group relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics and External Services

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

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.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

CONTACT US

If you have any questions about this privacy Policy, please contact us at: Group Lore, LLC, PO Box 440603, Aurora, CO 80044-0603, or info@grouplore.com.