Nexed s Privacy Policy tells you what information we use, collect or disclose to third parties about our users.

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1 ANSWERABLES BETA VERSION PRIVACY POLICY Effective Date: August 30, 2013 This Privacy Policy applies to the Answerables software, associated services and website located at its sub-domains and any associated web-based and mobile applications (collectively, Answerables ) and that are the property of Esquared Education Inc., its affiliates and any successors and assigns (collectively, Nexed ). Nexed s Privacy Policy tells you what information we use, collect or disclose to third parties about our users. We collect and use your information internally and may disclose your information to others, third parties outside of Nexed, in certain situations that are described in the Privacy Policy. The Privacy Policy addresses two kinds of information: (1) Personal Information; and (2) Anonymous Information. Personal Information identifies you as an individual, such as your first and last name, address, school, address, online contact information, image or audio of your voice. Anonymous Information does not identify you and can be combined with Anonymous Information about other users. 1. What Information we collect We collect your Personal Information as follows: Registration information: your first and last name, address, username and password that you provide when registering an Answerables account for yourself or when signing up for the Nexed newsletter, Nexed Notables. Your address: if a child under the age of 18 provides your address to Nexed in order to notify a parent or guardian of the child s desire to register an Answerables account. If you register an Answerables account for your child: your child s first and last name, username and password. You may choose to provide your child s address.

2 If you are over the age of 18, the transaction information you provide when you buy an Answerables license, account subscription, account features, Answerables credits or virtual items or verify that you are a parent or guardian of a child under the age of 13, and includes your first and last name, address, phone number, and credit card payment information ( Transaction Information ). When assisting you with technical support or responding to feedback you provide: your user name, address, account information and any other information you choose to provide. We collect your Anonymous Information as follows: Location data derived from cookies: what pages you viewed, how long you were on a particular page or whether you clicked on a link. A cookie is a small file we place on your computer and acts as a unique identifier. A cookie does not allow us access to your computer or any information about you, other than the data you choose to share with us. By declining to accept cookies you may not have access to Answerables features. Information about your computer system, or mobile device, that Answerables software is installed upon, including: the amount of RAM, the processor manufacturer and model, number of processors, graphics card manufacturer and model, amount of graphics card RAM and your computer or mobile device operating system. Your web browsing history for any websites visited from within Answerables. Answerables in-game statistics including clicks on features and buttons, virtual locations visited, attempts at missions and other features, missions undertaken and text chat logs. Answerables diagnostic information including logs, errors and events and the type, number, date and in-game location relating to this information. 2. How we use your Information

3 We use your Personal and Anonymous Information internally to understand your needs and provide you with better service and information, in particular: Internal record keeping: to establish and update user accounts. Answering questions: to respond to queries you have sent to us. Improving or expanding our educational content and offerings, including software and services. Promotion: we may periodically send promotional s about our new products, special offers or other information. Educational and market research: from time to time, we may use your information to contact you by or mail for market research purposes or educational studies. We use traffic log cookies to identify which website pages are being used. This helps us analyze data and improve our offerings in order to tailor them to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. We use your Transaction Information to facilitate the processing of your payment by third parties and it is not used for any other purpose. 3. Who we Disclose Information to We disclose your Personal and Anonymous Information as follows: If you are a child under the age of 18 and your parent or guardian registered an account for you, your parent or guardian can view all information within or associated with your account, including messages between you and other users and any other information contained in your account. If you are a child under the age of 18 and your parent or guardian consented to, or registered you for, an account provided by a school, school district, tutoring centre, educational business, or business related to education, or an affiliate thereof, your parent or guardian and teacher can view

4 all information within or associated with your account, including messages between you and your teacher, courses you are enrolled in and grades you received on assignments. Answerables includes integral text, audio and video chat features that allow you to communicate with other users. By using these features, you disclose the text you type, your image through video or audio of your voice to third parties. Except as Nexed permits, you are not permitted to use the chat features to disclose Personal Information as this information could be collected or used by other users. We are not responsible for any Personal Information you choose to disclose to other users. We disclose your Transaction Information to third parties for the purpose of processing your payment and for fraud prevention purposes. To respond to inquiries from law enforcement or to defend our rights or the rights of others. 4. Third Party Software and Services Use of Answerables may involve third party software and services, including third party websites. Answerables allows users, including Nexed, to provide links to any third party website located on the Internet. Use of third party software and services, including websites, may disclose your Personal or Anonymous Information to third parties. The Privacy Policy only applies to information that Nexed collects, uses or discloses and does not apply to the collection or use of your information by third parties through third party software or services. Use of third party software or services in Answerables may require you to accept a third party s terms of service/use or privacy policy. It is your sole responsibility to determine whether any third party privacy policy is acceptable to you. 5. Safeguarding Children s Privacy If you are a child under the age of 18, you may only use Answerables and disclose Personal Information to us after your parent or guardian registers an Answerables account for you or consents to a third party

5 such as a school, school district and or teacher registering an account for you. Please do not send any Personal Information other than what we request from you in connection with Answerables. Review the Privacy Policy with your parent or guardian and make sure you understand it, and do the same with the privacy policies of all websites and apps you use. We only collect Personal information from a child under the age 13 after: a. we provide the child s parent or guardian direct notice by way of the parent s online contact information collected from the child and obtain verifiable consent from the parent or guardian. We verify consent by requesting that the parent or guardian provide Nexed with a valid credit card. Nexed charges 30 cents (in Canadian dollars) to the credit card in order to create an Answerables account for the child; or b. the child s school, district, and/or teacher has obtained parental consent for that child to use Answerables. We collect, use and disclose your child s Personal and Anonymous Information in the manner described above in Sections 1 through 4 of the Privacy Policy. If we learn that we inadvertently collected personal information from a child under the age of 13 without parental consent being obtained first, or if we learn a child under 13 has provided us Personal Information beyond what we request, we will delete that information as quickly as possible. If you are the parent or guardian of a child under the age of 13, you have the right to know what Personal Information we collect from your child, review this information, request deletion of this information or request that we cease collecting or maintaining this information. For additional information or to exercise this right, please contact us as provided in Section 8 of this Privacy Policy. Answerables incorporates text, audio and video chat features that your child may access and use to communicate with other users. Your child s image or voice may be disclosed to other users while using these features. Except as permitted by Nexed, users are not

6 permitted to use the chat features to disclose their Personal Information. Please speak with you child and instruct them to not disclose their Personal Information while using Answerables chat features as this information could be read, collected or used by other users. As with all online communication, please speak with your child about what communications are appropriate or inappropriate. We bear no responsibility for any Personal Information your child chooses to disclose using the chat features. Answerables incorporates third party software and services, including websites, which your child may access. Answerables users may link to websites and your child may access these websites. As such, Answerables allows your child to access the broader Internet. You should speak with your child about proper usage of the Internet, including which websites are appropriate or inappropriate. Speak with your child and instruct them to not disclose Personal Information using third party software or services as this information could be read, collected or used by third parties. We bear no responsibility for your child s use of third party software or services, including websites your child accesses within Answerables. 6. Security We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. Nexed uses industry standard SSL (secure socket layer) encryption to transfer private Personal Information. Only the Answerables software and services are publicly accessible, no additional ports are opened in our system s security groups other than required and any information stored in our databases is not publicly accessible and exists only on our internal network. 7. Updates Nexed reserves the right, at its sole discretion, to change or modify or to add or remove portions of the Privacy Policy at any time ( Updates ). Nexed agrees to notify you of Updates by and to make them available at You will be deemed to have accepted any Update by continuing to use Answerables. Unless Nexed states otherwise, Updates are automatically effective thirty days after being posted on

7 8. Contact Us If you have questions or comments about the Privacy Policy or Nexed s data collection in general, please send us an at privacy@nexed.ca or contact us by mail or phone: Address: Esquared Education Inc. ATTN: Privacy Policy 2140 Forestview Trail Oakville, ON L6M 3W5 Canada Phone: Please Note: You must be at least 18 years old to contact Nexed by phone. If you are under the age of 18, you must have your parent or guardian s permission before phoning Nexed. All Personal Information you provide via , mail or phone will be kept confidential.