Tally Town Privacy Policy
Nuat Computer Software LLC (“Nuat Games,” “we,” “us”), owns and operates the Tally Town application (“Tally Town”) providing game-based curriculum for children. This Privacy Policy is meant to help our education institution customers (“Customers”), educators, parents, and students (which we refer to collectively as “Users,” “you,” and “your”) understand how we may collect, use, and disclose your Personal Information and your rights and choices related to that Personal Information. When Tally Town is used in schools, our collection, use, and disclosure of Personal Information may also be governed by a contract we have with the Customer.
In this Privacy Policy, when we refer to Personal Information we mean information that identifies, describes, or relates to a person or that is reasonably capable of being associated with or could reasonably be linked – directly or indirectly – with a person. By accessing or using Tally Town, you acknowledge that you have read and understood this Privacy Policy.
Personal Information We Collect
Tally Town may be used in education institutions or in the home. To provide access to Tally Town, we require the following Personal Information:
From Teachers:
We collect the first and last name, email address, and a username and password from teachers in order to create their accounts. In addition, teachers are able to send messages to their students within Tally Town. Teachers also provide names, account names, and passwords for each of their students to use as log in credentials.
From Students:
We automatically collect information about each student’s progress in Tally Town in order to be able to inform teachers about their students’ progress. We also automatically collect a persistent identifier from students so that we can better understand how Tally Town is used and to provide certain security features for Tally Town. You can learn more about our collecting of persistent identifiers in the section below on Information We Collect Automatically From Users.
Individuals Under Age 13
Tally Town is intended for use by children and students under the age of 13. We collect only the minimally required Personal Information from Users under the age of 13 for us to operate Tally Town, and we do not condition such Users’ access to or participation in Tally Town on providing more Personal Information than is necessary. We do not make Personal Information we collect from Users under 13 publicly available. However, student progress in Tally Town is made available to their teacher.
Personal Information collected from Users under age 13 is retained only for as long as is necessary to provide Tally Town. Further information on our data retention policy is provided in the Data Retention section below.
Our collecting of Personal Information from Users under age 13 is limited to a persistent identifier in the form of the Internet Protocol (“IP”) address. Under the Children’s Online Privacy Protection Act (“COPPA”), we are permitted to collect this persistent identifier when we limit the use to certain specific internal operations. We limit our use of the persistent identifier collected from Users under age 13 to these internal operations purposes:
1. Maintain and analyze the functioning of Tally Town - 2. Perform network communications - 3. Authenticate Users of Tally Town - 4. Help protect the security and integrity of Tally Town and our Users.
To the extent that other Personal Information is collected in the future, we will first provide the necessary disclosures and request prior consents as required and in the manner required under COPPA..
Parent Rights
Parents have the right to request to access, amend, and delete their child’s personal information. When the child is using Tally Town in an education institution, parents wishing to exercise their rights should contact their education institution. We will work directly with our Customer to help address those requests. Parents whose child is using Tally Town outside of an education institution may contact us to request to exercise their rights. Please be aware that we may request additional information to verify that you are the parent prior to fulfilling any rights request.
Family Educational Rights and Privacy Act (FERPA)
For our education institution Customers subject to the Family Educational Rights and Privacy Act (“FERPA”), we ask the Customer to agree that Nuat Games has a “legitimate educational interest” in providing Tally Town, and to designate Nuat Games as a “school official” as the terms are used in FERPA §§ 99.31(a)(1). Nuat Games shall remain under the direct control of the Customer with respect to the use and maintenance of FERPA-protected “education records,” and shall use student Personal Information only as described in this Privacy Policy and in any contract with the Customer, and in compliance with applicable law.
Information We Collect Automatically From Users
When you access Tally Town, our servers automatically collect a persistent identifier in the form of the Internet Protocol (“IP”) address associated with your browser. We may also collect additional information such as login timestamp, browser type and version, the operating system of the device, general, high-level location such as the country or state where you are located, as well as areas in Tally Town visited most often and the time spent. We use this information to help us provide Tally Town, to authenticate users, diagnose technical problems, and to provide security. We also aggregate this information in a way that doesn’t identify any individual. We use that aggregated information to analyze and understand trends about how Tally Town is used and to help us improve Tally Town.
To collect this information, we use Clicktracking. Clicktracking allows us to capture “clickstream data” about your use of Tally Town. This includes information about what actions you take in Tally Town, such as what you see or click on during your visit and how you interact with certain features. This can include information such as the order in which you click on buttons or links on a page, and it allows us to develop insights about how you move through Tally Town, remember your preferences within Tally Town, and understand how our Users interact with Tally Town.
Most browsers can be set to detect browser cookies and to let you reject them. To learn more about browser cookies, including how to manage or delete them, refer to the Tools, Help or similar section of your web browser.
Third Party Tracking
To collect the information that helps us understand how Tally Town is used and to analyze trends about that usage, we use Google Analytics and a software development kit (“SDK”). To learn more about Google Analytics, please see the Google Analytics Privacy Policy and the Google Terms of Service. Please note that we are not responsible for their browser add-on.
How We Use Your Personal Information
We do not sell or rent your Personal Information, and we do not serve Targeted Advertising.
- To provide Tally Town, including to create User accounts, authenticate Users, maintain and administer Tally Town, and to provide reporting and analytics for us and for our Customers on use of Tally Town.
- To provide customer support, including to resolve a problem or support issue, notify Customers about changes to Tally Town, and to otherwise communicate and solicit feedback on Customer experiences with Tally Town.
- To protect our rights or the rights and safety of our Customers and Users, or as necessary in the event of a court order, regulatory inquiry or other lawful request. Note that unless legally prohibited, we will direct any such request to the Customer or notify the Customer before responding..
- In relation to a known or suspected violation of our terms of use, fraud prevention or other unlawful use, including to share Personal Information with third parties helping us in an investigation and as may be required by applicable law.
- In the event of a reorganization, merger, sale, assignment, bankruptcy, or similar business change we may need to transfer your Personal Information to that re-organized entity or new owner after the sale or reorganization for them to use in accordance with this Privacy Policy.
- To provide our Customers with updates and offers from Nuat Games. At any time, you may unsubscribe or opt-out of further communication on any electronic marketing communication by using the link labeled “unsubscribe” available in each email communication or by contacting us at info@nuatgames.com (We do not send marketing to children or students).
We may create deidentified data from Customer and User information by removing, obfuscating and/or otherwise altering the Personal Information. We use deidentified data for purposes allowed by law, including developing and improving our educational products and to demonstrate the efficacy of Tally Town, including in our marketing materials.
Where We May Share Your Personal Information
We engage with third party partners to help us deliver Tally Town and to provide certain features on our behalf, such as data hosting, analytics, content delivery, maintenance, security, and similar functions. These third parties may require a limited amount of information, including Personal Information, in order to deliver their services. The third parties we currently share Personal Information with and why are:
How You May Modify Your Information
Teachers may access the Personal Information they provided to us via their in-game dashboard. Teachers who wish to correct or request deletion of Personal Information may do so by contacting us at info@nuatgames.com - Students or their parents may ask the education institution Customer to access, amend, correct or delete their Personal Information by contacting their education institution. We will partner with our Customers as needed to respond to those requests in the time requested by the Customer or otherwise as required by law.
Parents wishing to correct, change, or request deletion of their child’s Personal Information when Tally Town is used outside of an agreement with the education institution may do so by contacting us at info@nuatgames.com - Please note that to protect the privacy and security of our Users, we may request additional information to verify your identity and relationship to the child prior to facilitating your request.
Security
We maintain physical, administrative, and technical safeguards designed to help protect the confidentiality, availability, and integrity of the Personal Information in our care. However, the Internet is not perfectly secure, and we are not responsible for security breaches not reasonably within our control.
Data Retention
We retain Personal Information on servers located in the United States for as long as is necessary to provide Tally Town. Within 45 days after termination of a Customer agreement we will securely destroy the Personal Information described above.
At any time upon termination of an agreement or otherwise at their discretion, Customers may submit a written request to have their Users Personal information deleted. We will comply with such written requests within 45 days.
We may retain certain Customer information contained in business records for lawfully required business record-keeping purposes, however this does not include student or educator personal information. We may also retain certain Personal Information in our security logs as necessary for security purposes. That Personal Information shall be deleted in accordance with our security log deletion schedule.
We do retain non-personal information, including aggregated, de-identified data for the purposes described in the section above titled, “How We Use Your Personal Information.”
Opt-Out Policy
We send emails to Customers with information about our products and services that we believe may be of interest. Customers may opt out of receiving email messages from Nuat Games by contacting us at info@nuatgames.com or by clicking on the “unsubscribe” link found at the bottom of every email that we send. We do not send these emails to children, including students. If Customers have opted out of receiving communications from us, we may still send essential communications regarding Tally Town. We do not send email messages on behalf of third parties.
Updates to This Policy
As Tally Town evolves, we may make changes to this Privacy Policy. We will alert you to changes by providing notice within Tally Town or otherwise as required by law. When working with Customers, we will not make material changes to this Privacy Policy without first providing notice to and obtaining consent from the Customer.
The “last updated” note at the top of this policy indicates when it was last revised, and updates will become effective when they are posted.
Contact
If you have any concerns or complaints about how we handle your personal information, or if you have questions regarding this Privacy Policy, please contact us at:
NUAT Games
info@nuatgames.com
105, Swiss Tower, Cluster Y, Jumeirah Lake Towers, Dubai, Dubai 9742, AE
Users Outside of the US
Tally Town is currently available to Users in the United States. If you are located outside of the United States, you acknowledge that, in using Tally Town, your Personal Information will be transferred to, processed and stored in the United States. You further acknowledge that we may transfer, process and store your Personal Information as described in this Privacy Policy, and that your Personal Information will generally be treated in accordance with the applicable privacy laws of the United States. These laws may be different from the privacy laws in your country. However, this does not change our commitment to safeguard your privacy, and we will comply with all applicable laws relating to the cross-border disclosure of your Personal Information.