Elernity is also committed to protecting the privacy of our users, including Children. Please see the Children's Privacy and Parental Controls – Section 9 below and Section 12 regarding personal data of minors, 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. In order for Children to participate on the Platform, no personally identifiable information is collected from a Child until such time as verifiable parental consent is received from the Child's parent or guardian. In order to register on our site as a user, the Child's parent or guardian must activate their account.
If you are an EU resident, this whole Policy applies to you. However, EU residents should see Section 12 below, which will inform you in detail about the personal data 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 data and what rights you have regarding the processing of your personal data.
For users based in the European Union:
If you are a user based in the European Union, you may also contact our Representative in the European Union: email@example.com.
A."Personal data" means any information relating to 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, an online identifier, including but not limited to a name, e-mail address, telephone number, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
B."Processing" means any operation which is performed on personal data, such as collection, recording, organization, structuring, storage, adaptation or any kind of disclosure or other use.
Edbox works like this:
A user establishes an account by creating a username, password and a virtual character that is his or her identity when using the Service.
Registered users may interact with other users through in-game or website chat, personal messaging (within the Platform environment), user forums, groups, and other similar features, with available privacy settings designed to allow users to restrict or disable communications with other users.
Users may search for, find, and play games made by other users; they play these games with other users from around the world, and are identified only by their username.
The Edbox world may include a virtual currency; users can earn or purchase the virtual currency in a variety of ways and use them to buy or sell items for their characters, for in-game items, and other uses.
Users may be able to purchase premium services, including monthly or yearly subscriptions.
Users who want to save play statistics, share models, create games, and participate in the virtual economy, if provided for by the Platform, must create an account on the Platform. To create an 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, country or language preference (so we can customize your experience on the Platform).
Users must not create a username that reflects their own name or other personal data. Users should also not pick a password that is easy to guess and should not share their password. For security reasons, we store passwords in encrypted form.
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 not passed along to third-party companies except for our third-party service providers who use or process the usernames for purposes of helping operate our Service, such as effectuating payments and website hosting.
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 Edbox to check the authenticity of an account owner. In this circumstance, users under the age of 13 (or 16 in the European Union) are required to provide a parent email address to allow us to obtain verifiable parental consent. 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.
In addition to account setup on the Platform, we may collect and process information from you in connection with the following features and activities (as applicable):
When you make purchases on the Service. Users may be able to purchase virtual currency or premium subscriptions and use a variety of payment methods. When making purchases, users or their parents may be required to enter billing information, including name, billing address, credit card or other payment information, and billing email. The Platform may also retain your billing information, transaction details, and purchase history to resolve subsequent billing disputes and inquiries. The Platform does not retain the full credit card numbers of our users.
When you post or otherwise transmit comments or messages on the Platform via community features such as public chat or private chat, forums, group walls, personal posts, etc. we may collect these comments and messages, and they may be monitored, filtered and moderated for purposes such as removal of profanity, personal data, and other inappropriate conversations. We may use pre-filtered chat, comments and messages for purposes such as training and improving our filter technology.
When you provide us with your phone number, you may receive a verification SMS after sign-up to confirm your ownership of the number, which will allow you to login via mobile. Your phone number may also be used to recover a lost or forgotten password.
When you contact or send communications to Elernity, for example when you contact customer support, report a problem, or submit questions, concerns, or comments regarding our Service or its content, in which case 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 use or interact with third-party plug-ins that may be available on the Service, such as third-party social media widgets, share buttons, and/or login mechanisms. These features may include social plugins from Google, Facebook, Twitter or other platforms, and may be subject to the privacy policies of these other companies as posted on their respective websites. When you use these features, certain information from your social media accounts may be accessed by or shared with the Platform, and likewise, certain information about your use of the Platform may be posted to your profile on those platforms.
When you participate in contests, competitions, sweepstakes, giveaways, prize draws or other promotions that we may run on our Service or sponsor from time to time. These promotions may involve the collection and use of certain contact information (such as your name, email address, and/or phone number) for prize fulfillment purposes, as well as other information or content needed for the specific promotion. For certain contests or sweepstakes, we may ask for the email address of the Child's parent or guardian to inform the parent or guardian of his or her child's entry and give the parent or guardian the option to have the child's entry deleted.
When you respond to or participate in voluntary surveys, which we may offer on our Service from time to time to conduct research or demographic studies. These surveys may collect anonymous information about your likes and dislikes, game play interests and habits, general hobbies and interests, and other lifestyle information or preferences. These surveys will not collect personal data about you.
When you request or agree to location-based services from the Platform. We may collect or track real-time or precise geolocation information to provide services such as tagging, check-in and content delivery, targeted or geo-based advertising, or other services that are dependent on knowing where you are. This information may be collected in combination with an identifier associated with your device to enable us to recognize your mobile browser or device when you return to the Service. You can always stop the collection of location information by updating your device settings, stopping to use the Service, and/or un-installing our mobile applications.
When you subscribe to other features or activities that we may offer from time to time on the Service and submit or upload information in connection with such features. The data being collected for such features and their intended uses will be evident at the time of data collection.
When you browse, navigate, or otherwise interact with the Service, as outlined in the "Cookies and Similar Technologies" section below.
You are under no obligation to provide personal data to the Platform 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 deliver advertising that may be relevant to your interests;
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.
Elernity may share your information as set forth below. Please note that Elernity does not sell personal data about you to third-party companies for their marketing purposes.
Agents and contractors
Elernity may share users' information, including personal data like billing information or usernames, with our third-party agents, contractors, or service providers who are hired to perform services on Elernity's 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:
Public forums and community areas
We offer users the ability to use forums and similar means of public discussion. If you use any messaging, posting, or chat functions on the Platform, you should be aware that any personal data submitted there will be available to anyone who has access to that content, including other users, and can be read, collected, or used by other users of these forums, and could be used to send unsolicited messages. We are not responsible for how other individuals use the information posted in this manner.
We may disclose personal data 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 data about you in response to a request from law enforcement agencies, regulators, or other public agencies (including schools or children services) or if such disclosure may prevent the instigation of 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.
Information about our users, including personal data, 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 necessary, we will inform you of such disclosure and obtain your consent.
We share aggregated, automatically-collected, or otherwise non-personal data 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. We do not share personal data about you in this case.
The security of your personal data is important to us. When you enter sensitive information (such as credit card numbers) on our order forms, Elernity (or the service provider operating the function on our behalf) will encrypt that information using secure socket layer technology (SSL) or similar technologies. 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 data 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. Please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure.
Elernity may retain users' account data internally for the following purposes:
Billing information and transaction histories are retained to resolve subsequent billing disputes and inquiries;
Publicly shared content and game items are retained for use by the community (e.g., a user-created virtual item sold or provided to another user is kept in the system because the recipient now "owns" a copy of that item);
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 comply with 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.
Student Users Under the Age of 13 (or 16 in the European Union)
We require verifiable parental consent before we collect personal information through the Services from a student under the age of 13 (or 16 in the European Union). Where a student's school, district, and/or teacher wishes to use the Services for educational or learning purposes, the school, district, and/or teacher must first obtain parental consent for the student's use of the Services and represent and warrant to us that you (the school, district, and/or teacher) has the authority to provide to us personal information, including the personal information of students, for the purpose of the Services, and that you (the school, district, and/or teacher) have provided all appropriate or required disclosures to school or district administrators, parents or legal guardians and students regarding the sharing of student personal information with the Services. If you are a student under the age of 13 (or 16 in the European Union), please do not send any personal information about yourself to us if your school, district, and/or teacher has not obtained this prior consent from your parent or guardian, and please do not send any personal information other than what we request from you in connection with the Services. If we learn we have collected personal information from a student under the age of 13 (or 16 in the European Union) without having obtained parental consent or if we learn a student under the age of 13 (or 16 in the European Union) has provided us personal information beyond what we request or require, we will delete that information as quickly as possible. If you believe that a student under the age of 13 (or 16 in the European Union) may have provided us personal information in violation of this paragraph, please contact us at firstname.lastname@example.org.
Non-Student Users Under the Age of 13
For all other Children, we recognize that Children deserve added protections with regard to their personal data and privacy online. For this reason, when users under the age of 13 register for the Service, their account is automatically set to prevent the collection of personal data until we have received verifiable parental consent. This means that Child users under 13 will not have access to the system until their parent or guardian has provided verifiable parental consent.
To make any requests for changes to your Child's account or requests for the removal of personal data 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 data in connection with the Service (as applicable), please contact us at email@example.com.
We recommend that parents familiarize themselves with all of the safety features and parental controls available in the Settings area of the Service and to accompany their children when they are playing online.
All text is filtered for profanity, phishing, and adult or suggestive content. Our system uses a combination of human and automated processes. However, like all filtering technology, our systems are not 100% effective.
Parents should contact Elernity immediately if they have any concerns regarding the Service. Please see the Contact Information section below for further details.
If personal data about you changes, or if you no longer desire to use our Service, you may correct, update, or amend your account under your account settings and you may correct, update, amend, or deactivate your account by contacting Elernity using the information set out above in Sec. 1. We will respond to your request within a reasonable timeframe. For parents access to Child data, please see the Children's Privacy and Parental Controls Section 10 above.
Your personal data, which we collect, are sent to and stored on secure servers located in the United States of America. Such storage is necessary in order to process the information.
Elernity operates globally and we may transfer the personal data that we collect from you to our other offices and/or to the third parties mentioned in the circumstances described above in Section 7 (Information Sharing), which may be situated outside of your country or regional area and may be processed by staff operating outside your country or regional area. 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 country of residence. Wherever we transfer your personal data, we will take reasonable steps to protect your personal data, ensure an adequate level of protection, and have appropriate safeguards for our users' rights and legal remedies.
In the course of visiting our websites and/or apps, and/or using our services and products, we may process the following personal data in accordance with a legal basis listed in Article 6, Section 1, a - f:
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 our apps and/or our online services. The legal basis for this processing activity is the performance of a contract and 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 data 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 the performance of a contract.
Email addresses you provided us with for added verification and/or to enable certain features. The basis for processing this personal data is the performance of a contract and our legitimate interest of providing a safe and secure Platform, especially to protect Child users.
Billing and payment information, when you purchase virtual currency or premium subscriptions, including your name, billing address, credit card or other payment information and billing information. The legal basis for this processing activity is the performance of a contract. We may also retain transactions details and purchase and payment history. The legal basis for processing these personal data is our legitimate interest in being able to resolve subsequent billing disputes and inquiries.
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 (implicit) consent and in the performance of a contract, depending on the initial purpose for contacting our customer support.
Comments or messages you post or transmit on the Platform via public chats, forums, group walls, personal post, etc. We process this information to monitor, filter and moderate this information for the purposes of being able to remove profanity, personal data, and other inappropriate conversations. Additionally, we may use pre-filtered comments and messages for other purposes such as training and improving our filter technology. The legal basis for this processing activity is Elernity's legitimate interest in being able to defend ourselves from possible liability claims that may arise from unlawful comments posted by you. Please note that any personal data submitted by you in forums and similar means offered by us is available to anyone who has access to this forum including other users. The personal data posted by you can be read, collected or used by other users of these forums and could be used to send unsolicited messages.
Information relating to your use of or interaction with third party plug-ins, e.g. social plugins from Google, Facebook or Twitter. When you use these features, certain information from your social media accounts may be accessed by or shared with Elernity, and likewise, certain information about your use of the Platform may be posted to your profile on those platforms. The legal bases for this processing activity is based on your consent and our legitimate interest to improve your website experience and to optimize our service.
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 data 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 Elernity's legitimate interest in maintaining our user base, bringing new users to our websites and informing (potential) users about interesting events.
Information relating to the use of location-based service. In order to provide service such as tagging, check-in and content delivery, targeted or geo-based advertising or other services that require knowing where you are, we may process your location information. This processing is based on our legitimate interest to improve your website experience and to optimize our services. Please note that you can always stop the collection of location information by updating your device settings, stopping to use the Service, or un-installing our mobile applications.
Information relating to your participation in contest, competitions, sweepstakes, giveaways, prize draws or other promotions that we may run on our Service or sponsor from time to time. We may process certain contact information (such as your name, email address, and/or phone number) for prize fulfillment purposes, as well as other information or content needed for the specific promotion. The legal basis for this processing activity is based on the performance of a contract.
Please note that we do not use your personal data for automated decision making which produces legal effects concerning you or similarly significantly affects you.
Personal data of minors
Please note that when users under the age of 13 register for the Service, their account will not be created until we obtain verifiable parental consent. This means that these users will not have access to the Service and personal data will not be collected until the parent or guardian provides consent.
Elernity may share users' information, including personal data like billing information or usernames, with our third-party agents, contractors, or service providers who are hired to perform services on Elernity's 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:
We may disclose personal data about you, including the content of your communications on the Service, to comply with legal process, including court orders and subpoenas, served on our Service. In addition, we also may disclose personal data about you, including content, in response to a request from law enforcement agencies, regulators, or other public agencies (including schools or children services), or if such disclosure may (i) prevent the instigation of a crime, (ii) facilitate an investigation related to public safety or protect the safety of a child using our Service, (iii) protect the security or integrity of our Service, or (iv) enable us to take precautions against liability or to protect our rights. The legal basis for such disclosure is Article 6 sec. 1 sent. 1 lit. c ("compliance with legal obligation") and lit. f ("legitimate interest") GDPR. It is our legitimate interest to comply with the legal requirements of EU Member States and U.S. law.
Storage and international transfer of your personal data
Your personal data that we collect is sent to and stored on secure servers located in the United States of America. Such storage is necessary in order to process the information.
Some of our agents and third-party service providers are located outside the European Union, e.g. the United States. The data protection laws of the United States or other countries may not be as comprehensive or equivalent to those in your country of residence. Wherever we transfer your personal data, we will take reasonable steps to protect your personal data, ensure an adequate level of protection, and have appropriate safeguards for our users' rights and legal remedies.
If you are a user based in the European Union, you may be entitled to exercise some or all of the following rights:
Require (i) information whether your personal data is retained and (ii) access to or duplicates of your personal data retained, including the purposes of the processing, the categories of personal data concerned, and the data recipients as well as potential retention periods;
Request rectification, removal or restriction of your personal data, e.g. because (i) it is incomplete or inaccurate, (ii) it is no longer needed for the purposes for which it was collected, or (iii) the consent on which the processing was based has been withdrawn;
Refuse to provide and – without impact to data processing activities that have taken place before such withdrawal – withdraw your consent to processing of your personal data at any time;
Object, on grounds relating to your particular situation, to processing of your personal data, in case such processing is either based on our or a third party's legitimate interests or on a performance of a task carried out in the public interest. In this case, please provide us with information about your particular situation. After the assessment of the facts presented by you, we will either stop processing your personal data or present you our compelling legitimate grounds for an ongoing processing;
Object to the use of your personal data for direct marketing at any time;
Take legal actions in relation to any potential breach of your rights regarding the processing of your personal data, as well as to lodge complaints before the competent data protection regulators; and/or
Require to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format. Where technically feasible you shall have the right to have the personal data transmitted directly from us to another controller.
You may (i) exercise the rights referred to above, (ii) pose any questions, or (iii) make any complaints regarding our data processing by contacting us under the contact details set out above in Sec. 1.
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 Edbox.101.com domain); or
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 (mainly 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.
Third party advertising and ad networks
Cookies used by Edbox
The following lists enable you to recognize the cookies placed on your browser when you visit Edbox's websites or see adverts for us elsewhere. Although we strive to list all cookies used by us or our technology partners, if you find a discrepancy or think that a cookie has been omitted, please contact us at firstname.lastname@example.org.
|Nation||Help users switch to the server of the country where users frequently log in.||Permanence|
|Languages||Help users choose the language they use often, reducing unnecessary operations of users.||Permanence|
|Account ID and Token||The user can choose to save the authentication information and no longer need to enter the password for a period of time. (The default storage time can be adjusted, the user can also actively clear, and the token will automatically expire after 30 days).||Account ID: Currently permanent
(Adjustable, active clearance mechanism is also available)
Token: current 30 days
(Adjustable, active clearance mechanism is also available)
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,
Safari (Desktop): https://support.apple.com/kb/PH5042?locale=en_US,
Safari (Mobile): https://support.apple.com/en-us/HT201265,
You can also learn more about cookies by visiting 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 or play the games.