Privacy Policy

At Royelles Inc., we prioritize the privacy and safety of our users, particularly children under 13. This policy outlines how we collect, use, and protect personal information in compliance with the Children’s Online Privacy Protection Act (COPPA) and KidSAFE Seal Program guidelines. BY USING OUR SERVICES, YOU AGREE TO THE TERMS OF THIS POLICY.

1. Introduction
Please read the following to learn more about the Royelles, Inc. Royelles Revolution ("Royelles") Privacy Policy. The Royelles website (Royelles.app) is intended for use by parents and Royelles's various related games, applications, features, content, widgets, or services (collectively with the website, the "Service") are intended for use by the whole family including young children with parental participation and supervision. Royelles recognizes the importance of protecting any information collected from the users (each a "User" or collectively, "Users") of its Service, and has adopted this Privacy Policy to inform its Users about the types of information Royelles gathers about a User online while using Royelles's Service, how Royelles may use that information, whether Royelles discloses it to anyone, and the choices a User has regarding use of and correction of the information.

THIS PRIVACY POLICY IS PART OF THE TERMS OF SERVICE WHICH YOU, OR IF YOU HAVE NOT REACHED THE AGE OF MAJORITY IN YOUR JURISDICTION, A PARENT OR LEGAL GUARDIAN, MUST READ AND ACCEPT ON YOUR BEHALF.

IF YOU, OR YOUR PARENT/GUARDIAN ON YOUR BEHALF, DO NOT WISH TO BE BOUND BY THE TERMS OF SERVICE, INCLUDING THIS PRIVACY POLICY, PLEASE EXIT THE SERVICE NOW AND DO NOT DOWNLOAD, ACCESS, OR USE ROYELLE's SERVICES.

2. About Royelles and this Privacy Policy
Royelles is a revolutionary platform, where users are encouraged to create, explore, learn, interact and activate their potential. As a user of the Royelles platform, you and your friends can explore the possibilities that exist for you in leadership, science, tech, engineering the arts and math through play. Your privacy is important to us; this is why we created this Privacy Policy so that you are aware of what information is collected, how we use it, and who we share it with.
This Privacy Policy covers our websites on the royelles.com and royelles.app domain, our Royelles mobile app, the Royelles Revolution LIVE! Events and experiences, and our other websites, products, software, applications, content, data feeds and other services (“Service”) on which an authorized link to this Privacy Policy is posted. This Policy covers our practices regarding Royelles users of all ages, including a unique set of practices for those under the age of 13 (“children” or “child”). The Service is operated by or on behalf of Royelles Inc.

If you are an EEA resident, this whole Policy applies to you. However, EEA residents should see Section 16 below, which will inform you in detail about the personal information we process, how we process it, for which purposes we process it, with whom we share it, on what legal basis we process and transfer your personal information and which rights you have regarding the processing of your personal information.

Royelles is also committed to protecting the privacy of our users, including children. Please see the "Children Privacy and Parental Controls" section below for more information about your rights as a parent or legal guardian of our children users and the measures we take to afford children users with additional protections and comply with the Children’s Online Privacy Protection Act (“COPPA”). To learn more about COPPA, you may consult this website – https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule

If you have any questions, comments, or concerns regarding this Privacy Policy and/or data practices, please contact us at the following email address: hello@royelles.app

3. Deﬁnitions
“Personal Information” means any information relating to a natural person who can be identiﬁed, directly or indirectly, in particular by reference to an identiﬁer such as a name, an identiﬁcation number, location data, or an online identiﬁer.
“Processing” means any operation which is performed on personal information, such as collection, recording, organization, structuring, storage, adaptation or any kind of disclosure or other use.
Any other capitalized term that is not deﬁned in this Policy is deﬁned and has the meaning set out in our Terms of Use.

4. Information Collected on our Corporate Websites
Please note that our Corporate Websites (which may include royelles.com and their subdomains) are general audience websites. On these sites, we may provide information regarding the corporate side of Royelles, press information, career information, and other general audience information. We may also ask for your name, email address, employment details if you send us a CV, resume or other details of your employment history in connection with an advertised job vacancy or a general inquiry regarding employment opportunities with us and other information so that we can provide corporate-related information to you or respond to your job application. No game play happens on the Corporate Websites. As such, the parts of this Privacy Policy that discuss game play or discuss children are not applicable to the Corporate Websites.

5. How Royelles Works

Royelles works like this:

• A user creates a username and a virtual character that is his or her identity in the Royelles world.
• Registered users interact with a virtual character through in-game chat feature
• Each user is given access to stories and learning adventures that are called “games.”
• Users play games and are identiﬁed only by their username.

• The Royelles world includes virtual tokens that users can earn and use to unlock in-game items.
• For more information on how our service works, please see our Terms of Use.

6. Information You Provide when Setting Up an Account on Royelles

Registered users
All users must create a Royelles Account to play our games. To create a Royelles account, we will ask you to create a unique username and password (so you can log in to your account), and to provide other demographic information such as your age or date of birth, gender, regional location(so we can customize users experience on Royelles). The information shall enable us to determine the player base, so that Royelles can adjust our games to the legal requirements of the respective regional location.

Users are encouraged not to create a username that reﬂects their own name or other personal information. Users should also not pick a password that is easy to guess and should not share their password.
Usernames are used for participating in Service features, and we do not use them to identify individual users outside of their activities on our Service. Usernames are shared with the parties listed in Section 7 below.
Users may be asked to provide or may choose to add an email address to their account for added veriﬁcation and/or to enable certain features. The primary purpose for this email address is to provide account security, as this is the only way for Royelles to check the authenticity of an account owner. In this circumstance, children are asked to provide a parent email address. Users may change the email address associated with their account at any time; however, a notiﬁcation will be sent to the previously provided email address upon making that change.

7. Additional Personal Information You Provide When Using Royelles Features

In addition to account setup on Royelles, we may collect and process personal information from you directly if you use the following features and activities (as applicable):

• When you provide us with your phone number or email address. If you choose to provide an email address or phone number during registration, you may receive an email or veriﬁcation SMS after sign-up to conﬁrm your ownership of the number, which will allow you to log in via mobile. Your phone number may also be used to recover a lost forgotten password.

• When you use our games AR Face Filter features. For example, when you play our AR Face Filter games, we may collect your face’s physical movement information using ARKit and TrueDepth API in order to identify face features such as eyes and mouth and to replicate your face movement in the game. This information is used to provide the Service and is not stored or transferred out of your mobile device.

• When you contact or send communications to us. For example, when you contact customer support, report a problem, or submit questions, concerns, or comments regarding our Service or its content, we may collect contact information such as your email address and other important information about your inquiry or concern. This information is used to respond to your communications, fulﬁll your requests, or provide other customer support.

• When you browse, navigate, or otherwise interact with the Service. We collect information from your device when you visit our websites, as outlined in the “Cookies and Similar Technologies” section below.

When you respond to or participate in voluntary research or demographic surveys or studies. These surveys may collect information about your likes and dislikes, game play interests and habits, general hobbies and interests, and other lifestyle information or preferences. These surveys may ask for personal information.

You are under no obligation to provide personal information to Royelles when requested. However, if you choose to withhold any requested information, we may not be able to provide you with certain services and features. In addition to the speciﬁc uses above, any information that you provide or that we collect on the Service may be generally used for the following purposes:

• To operate, maintain, and improve the Service;
• To give you access to the Service and related features or restrict your access;
• To personalize the Service or content on the Service, as well as make it more user-friendly;
• To allow you to manage your account or account information, update your account settings, and (where applicable) make purchases or subscribe to services;
• To communicate with you about the Service (product changes, feature updates, etc.);
• To provide technical support or customer service;
• To detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and prosecute those responsible for that activity;
• To research technological development and demonstration;
• To identify and repair errors that impair existing intended functionality;
• To audit interactions, transactions, and other compliance activities; and
• To protect the integrity, safety, or security of the Service or our users, comply with legal obligations, or enforce compliance with our Terms of Service or other restrictions placed on your use of the Service.

8. Cookies and Similar Technologies
Like most websites, we use cookies and other standard Internet technologies to help us improve our Service.

A cookie is a small text ﬁle that is placed on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, for example so you don’t have to re-enter them whenever you come back to the website or browse from one page to another. A cookie can be classiﬁed by its lifespan and the domain to which it belongs. By lifespan, a
cookie is either a:

• Session cookie which is erased when the user closes the browser; or
• Persistent cookie which remains on the user’s computer/device for a pre-deﬁned period of time.

As for the domain to which it belongs, there are either:

• First-party cookies which are set by the web server of the visited page and share the same domain (in this case royelles.app domain); or
• Third-party cookies stored by a different domain to the visited page’s domain. This can happen when the webpage references a ﬁle, such as JavaScript, located outside its domain.

Pixel Tags/Web Beacons
A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about visitors’ engagement on that web page. The use of a pixel allows us to record, for example, that a visitor has visited a particular web page or clicked on a particular advertisement.

How we use cookies

When you visit or access the Service, we may – by means of cookies, beacons, tags, scripts, and/or other similar technologies-automatically collect technical information about the devices and software you use to access the Service, such as the type of Internet browser or mobile device you use, the website or source that linked or referred you to the Service, your IP address or device ID (or other persistent identiﬁer that uniquely identiﬁes your computer or mobile device on the Internet), the operating system of your computer or mobile device, and other similar technical information. These same technologies (or a combination of them) may also be used to help us:

• Capture and store users’ preferences, account settings, and certain login information (for convenience, user veriﬁcation, and account security);
• Compile statistics and analytics about your use of and interaction with the Service, including details about how and where our Service is downloaded from or accessed, how often a user visits or uses the Service, the date and time of user visits to, and actions on, the Service, which areas of the Service are visited and for how long, information regarding in-game activities, and other similar trafﬁc, usage, and trend data;
• Mobile analytic tools to allow us to better understand the functionality of our mobile software on your device and gain insights about how mobile software is used;
• Gather important functionality, testing, and performance data about our Service, including performance data related to our mobile application, such as networking activity, CPU load, and resource usage, among other relevant data;
• Moderate user behavior on the Service, such as protecting against payment fraud and other inappropriate activities;
• Gather demographic information about our user base; and

• Perform other similar functions

We will not use cookies or similar technologies other than for the purposes stated in this Privacy Policy.

Third party advertising and ad networks
Royelles partners with third-party advertisers, ad server companies, and ad networks (“third-party advertising companies”) to promote our Service. If you respond to one of our advertisements and visit or register to use our Service, we or our service providers may provide these third-party advertising companies with identiﬁers from your device or computer, such as an IP address or device ID, to help us analyze our user acquisition efforts.

Your choices
Most web and mobile device browsers automatically accept cookies, but if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. Some browser manufacturers provide comprehensive help relating to cookie management in their products. Please see below for more information:

• Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB,
• Internet Explorer: https://support.microsoft.com/en-us/help/260971/description-of-cookies,
• Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer,
• Safari (Desktop): https://support.apple.com/kb/PH5042?locale=en_US,
• Safari (Mobile): https://support.apple.com/en-us/HT201265,
• Android Browser:

https://support.google.com/nexus/answer/54068?visit_id=0-636612941590933601131731679&hl=en&rd=1, and
• Opera: https://www.opera.com/help.

You can also learn more about cookies by visiting https://www.allaboutcookies.org/, which includes additional useful information on cookies and how to block or delete cookies that are already on your computer.

Please note, however, that by blocking or deleting cookies used on the Service, you may not be able to take full advantage of the Service and you may not be able to log on to the Service.

9. Information Sharing
Please note that Royelles has not and does not sell personal information about you to third-party companies for their independent purposes. Royelles may disclose your information for a business purpose as set forth below.

Agents and contractors

Royelles may share some users’ information, with our third-party agents, contractors, or service providers who are hired to perform services on our behalf. These providers may operate or support certain functions of the Service. Below is an illustrative list of functions for which we may use third-party service providers and the names of the providers we may use to perform these functions:

• Analytics services (e.g., Google LLC, comScore, Flurry Analytics);
• Billing services and payment gateway providers (e.g., Google, Apple, Amazon, Paypal); and
• Hosting and content delivery network services (e.g., AWS).

These agents and contractors are only allowed to use the personal information shared with them for the speciﬁc tasks they’ve been hired to do and consistent with this Privacy Policy, and for no other purposes, and they are not permitted to sell the personal information shared with them. Royelles takes steps to ensure that all service providers with access to personal information are capable of protecting the information we share with them.

Legal disclosures
We may disclose personal information about you as required or permitted by law and/or comply with a judicial proceeding, court order, or legal process served on our Service. To the extent permitted by applicable law, we also may disclose personal information about you in response to a request from law enforcement agencies, regulators, or other public agencies (including schools or children services), or if we believe in good faith that such disclosure may prevent a crime, facilitate an investigation related to public safety or protect the safety of a child using our Service, protect the security or integrity of our Service, or enable us to take precautions against liability or to protect our rights.

Business transfers
Information about our users, including personal information, may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets. Where required by applicable law, we will inform you of such disclosure and obtain your consent.

De-identiﬁed information
We share aggregated, automatically-collected, or otherwise de-identiﬁed personal information with third parties for various purposes, including (i) compliance with reporting obligations; (ii) for business or marketing purposes; (iii) to assist us and other parties in understanding our users' interests, habits and usage patterns for certain programs, content, services, advertisements, promotions and/or functionality available through the Services.

Google Analytics
We use Google Analytics, a service of Google LLC (“Firebase” or “Google Analytics” or “Google”.) as described in “How Google uses information from partner sites or apps” . Google Analytics employs cookies that are stored on your mobile device to facilitate an analysis of your use of the app. The information generated by these cookies, such as time, place, and frequency of your visits to our app, is transited to Googles location in the US and stored there. All Google Analytics events on our app are generic and not speciﬁc to users. We do not track or send any personally identiﬁable data to Firebase.

10. Security and Data Retention
Security
The security of your personal information is important to us. We have security measures in place to attempt to protect the personal or other sensitive information submitted to us against the loss, misuse and alteration of personal information under our control. While we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use reasonable efforts to prevent it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

When using the Services or providing personal information to us, we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of an incident that may qualify as a breach under applicable law, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

Retention
Royelles may retain users’ account data internally for the following purposes:

• Billing information and transaction histories are retained to resolve subsequent billing disputes and inquiries;
• User account history is retained to support subsequent customer service inquiries and to provide, improve and develop the Services;
• To promote safety and security on and for the Services; and
• To resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with our legal obligations.

We may retain your information for as long as is necessary and relevant to your use of the Service and our operations, which may include retaining your information beyond the end of your use of the Service.

Account Deletion:

Users may log into the Royelles mobile application and navigate to the profile section to delete an account. Upon confirming account deletion, all personal information collected from the user will be permanently removed from the Royelles database.

11. External links
Our Service may, from time to time, contain links to external sites or applications. We are not responsible for the privacy policies or the content of such sites or applications. To make clear when you are linking to a third-party site or application, we may display a warning message informing you when you are leaving our Service.

12. CHILDREN’S PRIVACY AND COPPA COMPLIANCE

WE COMPLY WITH THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA) BY:

Collecting minimal data from children
Requiring verifiable parental consent
Allowing parents to manage their child’s data

For more details, refer to the PARENTAL RIGHTS section above.

9. KIDSAFE COMPLIANCE

To meet KidSAFE standards, we:

PROVIDE AGE-APPROPRIATE, EDUCATIONAL CONTENT FREE OF INAPPROPRIATE MATERIAL.
OFFER PARENTAL CONTROLS to monitor and manage their child’s use of our platform.
ENSURE A SAFE ONLINE ENVIRONMENT by monitoring user-generated content and interactions for compliance with community standards.
MAINTAIN TRANSPARENCY about the collection and use of children’s data.

We recognize that children deserve added protections with regard to their personal information and privacy online. When a child creates an account on Royelles, we may collect a username, password, birthdate, and parent’s email address. This information is used to give the child access to the Service (with certain default settings) and, if a parent’s email is provided, to communicate with the parent about the child’s account. For example, we may use the parent’s email to send an email notiﬁcation about the child’s account creation and an invitation for the parent to review, update settings, and approve of their child’s account.

We may use the birthdate the child provides when signing up for the Service to determine which features the child should have access to, and to determine when the child will be given broader access to features on our Service. In general, we will not use or share account information (including personal information) from your child’s account, except for the permissible purposes stated in this Privacy Policy, and, if required by law, only with the prior veriﬁable consent of a parent or legal guardian.

To make any requests for changes to your child’s account or requests for the removal of personal information collected about you or your child from our Service (as applicable), or to request that we stop the further collection or use of your or your child’s personal information in connection with the Service (as applicable), please contact us at hello@royelles.app.

We recommend that parents accompany their children when they are playing online. If you are a child, it is a good idea to talk to and ask your parent(s) or guardian(s) for permission before using or playing on the Service. If you do not get such permission, you should not use our Service.
Parents should contact Royelles immediately if they have any concerns regarding the Service, wish to review information collected from your child, or have that information modiﬁed or deleted.

13. Accessing and Updating Your Personal Information
If personal information about you changes, or if you no longer desire to use our Service, you may correct, update, amend, or deactivate your account under your account settings or by contacting Royelles using the personal information set out above in Sec. 1. We will respond to your request within a reasonable timeframe.

14. Storage and International Transfer of Your Personal Information
Royelles is based in the U.S. Your personal information which we collect is stored on secure servers located in the United States of America. Such storage is necessary in order to process the information.

Royelles operates globally and we may transfer the personal information that we collect from you to the third parties mentioned in the circumstances described above, which may be situated outside of your regional location, and may be processed by staff operating outside your regional location. In particular, information provided to us or collected by us likely will be transferred to and processed in the United States by us or our agents and contractors. The data protection laws of the United States or other countries may not be as comprehensive or equivalent to those in your regional location of residence. Wherever we transfer your personal information, we will take reasonable steps to ensure that your privacy rights continue to be protected.

Some of these rights can be exercised by updating your account within the Services, or you can contact us as set forth in Section1 above for other requests. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulﬁlling your request.

15. Additional Information for California Residents (effective January 1, 2020)

In accordance with applicable law, you may have the following rights:

Access to/Portability of Personal Information. You can receive a copy of categories of personal information and speciﬁc pieces of personal information we have collected about you in the past 12 months, consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic personal information in a portable format or transferred to
another party.

Correction. You can request correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information or we may refer you to the controller of your personal information who is able to make the correction.

Deletion. You can request we delete personal information we collect or maintain about you, subject to certain exceptions prescribed by law.

Restriction of or Objection to processing. You can request restriction or object to the processing of your personal information, and you have the right to opt in or opt out of the sale of your personal information to third parties, if applicable, where such requests are permitted by law.

16. Additional Information for EEA Residents
In the course of visiting our websites and apps, and/or using our services and products, we may process the following personal information:

• Login information, which may include your IP address, device type, name, date and time of your visit, information on your browser version, information on your operating system, including language settings, MAC addresses, and User ID. We will process this information to provide you with the websites, apps and our online services. The legal basis for this processing activity is Article sec. 1 sent. 1 lit. b (“performance of a contract”) and lit. f (“legitimate interest”) GDPR. It is our legitimate interest to guarantee the websites’ stability and security.

• Account information, e.g. information such as your name, username, login and password details, location information, user-generated content, contact details and other personal information that are used for participating in the Service feature we are offering. We process this information to provide our Services to you. The legal basis for this processing activity is Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”).

• Email addresses you provided us with for added veriﬁcation and/or to enable certain features. The bases for processing this personal data are Article 6 sec. 1 sent. 1 lit. b (“performance of a contract”) and f (“legitimate interest”) GDPR. Royelles has a legitimate interest of providing a safe and secure Platform, especially to protect children.

• Information relating to contacting our customer service, e.g. when you report a problem, submit questions, concerns or comments. We may process your email address, your name and information relating to your inquiry or concern in order to respond to your communications, fulﬁll your requests, or provide other customer support. This processing activity is based on your consent according to Article 6 sec. 1 sent. 1 lit. a GDPR and/or Article 6 sec. 1 sent. 1 lit. b GDPR (“performance of a contract”), depending on the initial purpose for contacting our customer support.
• Information processed to enable advertising. To market our services, inter alia, via social media platforms in order to bring new users to our websites and to maintain and increase our user base, we may process personal information such as IP addresses, information on users’ browser or operating system, including language settings, location information and user names or user IDs. The legal basis for the processing of this data is Royelle’s legitimate interest in maintaining our user base, bringing new users to our websites and informing (potential) users about interesting events, Art. 6 sec. 1 sent. 1 lit. f GDPR (“legitimate interest”).

17. Privacy Policy Changes and Updates
We may update this Privacy Policy to reﬂect changes to our information practices at any time, so please review it frequently. If we update this Policy, changes will be reﬂected on this page and we will update the “Last Updated” date posted below. If we make any material changes to this Privacy Policy, we will attempt to notify you by email (by sending an email to the email address speciﬁed in your account, if an email account is associated with your account), or by means of a prominent notice on this website prior to the change becoming effective. We will obtain prior parental consent if any changes we make to this Policy affect users under the age of 13 in a way that requires such consent under COPPA or the age of 16 in a way that requires such consent under the European General Data Protection Regulation.

Last Updated: November 1, 2024