Juego! Privacy Policy
Juego (“Juego,” “we,” or “us”) understands that privacy is tremendously important to our online visitors to our website (“Website Visitors”), to schools who use our Service (“Schools”), and to students whose information we may access on behalf of a School (“Students”). Juego provides a platform that enables Schools to provide enhanced educational services to its students. As we describe below, Schools decide which data is shared with Juego, and Schools are responsible for determining whether data is ever shared with any Juego systems or applications. This privacy policy applies to our website www.gojuego.com and to the Juego platform (our “Service”) and describes the steps we take to protect your data.
Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Master Services Agreement.
Click on the links below to jump to each section:
How We Collect and Use Information
Sharing of Your Information
How We Protect Your Information
Your Choices About Your Information
Children’s Privacy
Links to Other Websites and Services
How to Contact Us
Changes to Our Privacy Policy
Jurisdiction-Specific Disclosures
In certain jurisdictions, we are required by applicable data protection laws to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states. If you are a resident of the states of California, Colorado, Connecticut, Nevada, Virginia or Utah, or if you are located in the European Economic Area, Switzerland or the United Kingdom, Canada or Australia, please click on Jurisdiction-Specific Disclosures for additional disclosures that may be applicable to you.
We strive to be transparent in our data collection and use practices. This is the type of personal information we may collect. Student Data is used only for educational purposes at the direction of the School.
1. HOW WE COLLECT AND USE INFORMATION
We collect the following types of information:
Information about Schools: We ask for certain information when a School administrator registers a School with Juego, or if the administrator corresponds with us online, including a name, school name, school district, school email address and/or account name and password, phone number, message content, and information relating to the School’s information systems. We may also retain information provided by a School if the School sends us a message via email, online chat, telephone, teleconference or in person, posts content to our website or through our Service, or responds to emails or surveys. Once a School begins using the Juego Service, we will collect content and information provided by the School through the School’s use of the Service and we will keep records of activities related to the Service. We use this information to operate, maintain, and provide the features and functionality of the Service, to analyze and improve our Service offerings and functionality, and to communicate with our Schools and Website Visitors.
If a School uses Juego Identity Management (IDM), Juego will also access user data from the School’s identity provider to create, update, and archive user accounts in selected identity providers. This may include updates to account fields and an account’s membership in organizational units and groups. If the School sets up Google Workspace as a destination in Juego IDM, Juego’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
Student Data: Through the course of providing its Service to a School, Juego may have access to personally identifiable information about students (“Student Data“) that is provided by the School, by the parent or guardian, or by the Student. Depending on the features and functionality of the Service selected by the School, a School may authorize Juego to receive Student Data from a Juego learning application(s) that are used by the School. Juego has access to Student Data only as requested by the School and only for the purposes of performing Services on the School’s behalf. The type of Student Data we collect will depend on how the School uses the Service and the learning applications which the School connects through the Service. In many instances, Juego receives Student Data only from the School or its designated third parties and never interacts with the Student directly. In some instances, depending on the level of Juego’s Service selected by the School, the Schools may allow Students to log into the Juego Service to access Juego applications that have been authorized by the School. In that instance, the School provides each student with login credentials and provides consent for Juego to collect personal information directly from a student who is permitted to access the Service.
Student Data is used only for educational purposes at the direction of the School.
Juego does not own or control Student Data, and collects Student Data only subject to the direction and control of the School. We consider Student Data to be confidential and do not use such data for any purpose other than to provide the services on the School’s behalf and to maintain, support, evaluate, diagnose and develop our Services, in accordance with contractual agreements with the School. Our collection, use, and disclosure of Student Data is governed by our Master Service Agreement, and/or any other agreement with the School, by the provisions of the Family Educational Rights and Privacy Act (FERPA), the Children’s Online Privacy Protection Act (COPPA), and applicable state laws which relate to the collection of Student Data. If you are a Student or parent, please contact your School if you have questions about the School’s use of service providers like Juego.
See “How We Share Your Information“ below for more information on the limited ways in which we share School and Student Data. See “Children’s Privacy“ below for more information on how we collect and use the personal information of children under 13.
Information about Parents:
Depending on the features and functionality selected by the School, we may collect personal information about a student’s parent or legal guardian (a “Parent”) that is provided by the School or by the Parent if the Parent creates an account to access the School’s Juego Service. Please refer to the Additional Terms of Use for Parents to learn more about how we treat Parent personal information and accounts.
Information about Others:
We also collect personal information from Developers and other individuals who create an account, correspond with us online or otherwise use or interact with the Juego Service, including a name, contact information and information relating to the Developer business or service. We may also retain information if the Developer sends us a message via email or online chat, posts content to our website or through our Service, or responds to emails or surveys. Once a Developer begins using the Juego Service, we will collect content and information about the Developer’s use of and interaction with the Service and we will keep records of activities related to the Service. We use this information to operate, maintain, and provide to the features and functionality of the Service, to analyze and improve our Service offerings and functionality, and to communicate with our Developers and others.
Information collected through use of the Service:
We may collect information you provide or upload to the Service as well as activity and actions within our Service. For example, we collect information from files that you upload or content you post to the Service (such as in a classroom dashboard), messages you send or receive through the Service, and content you post such as in product reviews or comments. If you are a Developer, we will also collect information you make available to us when developing an Application via the Service.
Information collected through technology:
Like most websites and online services, we and our third-party partners automatically collect information you provide to us and information about how you access and use the Services and information about the device you use to access the Services. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, file information and similar technology (collectively, “tracking technologies”) and we may use third-party partners or technologies to collect this information. For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device, or your account, and other such information. We also collect information about the way you use our Service, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, the information you enter when you interact with the Service or engage in chat features through our Service, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service. When you access our Service from a mobile device, we may collect unique identification numbers associated with your device or our mobile application, mobile carrier, device type, model, and manufacturer, and mobile device operating system. We may be able to determine your approximate location by analyzing other information, like an IP address to associate a user with their School. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service.
All of the information collected automatically through these tools allows us to improve your user experience, monitor and improve the Service and improve the effectiveness of our Service, communications features and customer service functionality. For example, we may use the data collected through cookies to: (a) remember information so that a user will not have to re-enter it during subsequent visits; (b) provide custom, personalized content and information; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, and usage on our website and our Service; (f) diagnose or fix technology problems; (g) help users efficiently access information after signing in; and (h) otherwise to plan for and enhance our Service. On certain portions of our website, we and our third party partners may also collect device and usage data for purposes of tracking adult visitors to our websites and for other targeted advertising, attribution, research and analytics purposes. While we may permit third party advertising partners to collect information from visitors to adult-directed pages of our site (such as the support pages), we do not permit third party advertising networks to collect information about authenticated users our Service for the purpose of serving targeted advertising and we will never use Student Data for targeted advertising.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
Student privacy is very important to us. Student Data is only shared in limited circumstances – and never shared with or sold to third parties for marketing purposes.
2. HOW WE SHARE YOUR INFORMATION
Juego only shares personal information in a few limited circumstances, described below. We do not rent or sell information for marketing purposes and we will never share or sell Student Data with third parties for marketing purposes
Who we may share information with:
We share information within the Service as needed to perform the Service and/or at the direction of the School. For example, information including Student Data will be shared between and among authorized School users such as teachers and School administrators and will be shared with third parties such as specific Developers as directed and authorized by the School. This sharing will depend on the settings and functionality selected by the School.
We may share information with our trusted third-party service providers who perform technology services on our behalf (e.g., web hosting, chat providers, analytics services), but strictly for the purpose of carrying out their work for us. Contractors and service providers who may have access to Student Data in the course of performing their services are subject to confidentiality and data security requirements.
We may be required to share information with law enforcement or other third parties when compelled to do so by court order or other legal process, to comply with statutes or regulations, to enforce our Master Service Agreement, or if we believe in good faith that the disclosure is necessary to protect the rights, property or personal safety of our users.
We may share information in an aggregated and/or anonymous form that does not reasonably identify an individual or School. For example, we may use and share aggregate or anonymized data to study and improve our Service, user functionality, and product offerings.
In the event of a change of control: If we sell, divest or transfer our business, we will not transfer personal information of our customers unless the new owner intends to maintain and provide the Service as a going concern, and provided that the new owner has agreed to data privacy standards no less stringent than our own. In such case we will provide you with notice and an opportunity to opt-out of the transfer of personally identifiable Student Data.
How Student Data is shared: Other than the disclosures described above, Juego does not disclose Student Data other than as authorized and permitted by the School. We take strong measures to keep data safe and secure.
3. HOW WE PROTECT YOUR INFORMATION
Storage and processing: Any information collected through the Service from US residents is stored in the United States. Juego maintains strict administrative, technical, and physical procedures to protect information stored in our servers, which are located in the United States. Access to information is limited (through user/password credentials and two factor authentication) to those employees who require it to perform their job functions. We use industry-standard Secure Socket Layer (SSL) encryption technology to safeguard the account registration process and sign-up information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to buildings and files.
Unauthorized disclosure: If there is any disclosure or access to any personally identifiable Student Data by an unauthorized party that compromises the security, confidentiality, or integrity of the Student Data, we will promptly notify the affected School(s) and will use reasonable efforts to cooperate with their investigation of the incident.
4. YOUR CHOICES ABOUT YOUR INFORMATION
Account information and settings: Schools may update account information and modify Services by signing into the administrator account. Schools and other Website Visitors can opt-out of receiving promotional email from us by clicking on the “unsubscribe” feature at the bottom of each email. Sorry, you cannot unsubscribe from Service-related messaging.
If you have any questions about reviewing or modifying account information, contact us directly.
Access to Student Data: Student Data is provided and controlled by the Schools. If you have any questions about reviewing, modifying, or deleting personal information of a student, please contact your School directly.
How long we keep User Content: Following termination or deactivation of a School account, Juego may retain School profile information and content for a commercially reasonable time for backup, archival, or audit purposes, but any and all Student Data associated with the School will be deleted promptly. We may maintain de-identified or aggregated data, including usage data, for analytics purposes. We also may not be able to delete information that was previously shared with other users (such as through messages) or information previously shared with third-party applications. If you have any questions about data retention or deletion, please contact us at support@gojuego.com.
We do not collect any information from students without consent.
5. CHILDREN’S PRIVACY
Juego does not knowingly collect any information from children under the age of 13 (or the applicable age of consent in local jurisdictions) unless and until the School has authorized us to collect such information through the provision of the Service to Students on the School’s behalf. Because Juego collects and uses Student Data at the direction of and under the control of a School, Juego relies on each School to provide appropriate notice to parents of the School’s use of third party service providers such as Juego, and for the Schools to provide consent and authorization for Juego to collect personal information from children under 13, as permitted by the Children’s Online Privacy Protection Act (COPPA) and other applicable data protection laws. All personal information collected from or about a child under 13 is “Student Data” because when Juego collects personal information from a child on behalf of a School, the information is considered part of that child’s educational record and is under the direct control of the School.
Personal information collected from children
We intentionally limit the collection of personal information from children to only what is needed to provide the Service. Most of the children’s personal information collected by Juego is provided by the authorized School adult users, either manually or through an integration with School information systems, and is not collected directly from the children themselves. The type of personal information Juego collects from children depends on how the School uses the Service. If and when the School allows its Students to log into the Juego Service, Juego may collect: login credentials, authentication events, usage information about the child’s use of the Service and activities, such as login timestamps, logs of third-party application access, content or messages sent or received through the Service, information about the child’s interaction with third party Developers authorized by the School, and similar information. We also collect information about the browser or device used by the child to access the Service, including an IP address or other unique identifier. We may link or combine this information with personal information we receive about the Student from the School.
How we use and disclose personal information collected from children
We collect, use and disclose personal information from a Student under 13 for the use and benefit of the School and for no other commercial purpose.
Juego only shares personal information collected from or about a Student under 13 in a few limited circumstances, described below. We do not rent or sell information for marketing purposes and we will never share or sell a child’s personal information with third parties for marketing purposes.
We share information within the Service as needed to perform the Service and/or at the direction of the School. For example, information including Student Data will be shared between and among authorized School users such as teachers and School administrators and will be shared with third parties such as specific Developers as directed and authorized by the School. This sharing will depend on the settings and functionality selected by the School.
We share information with our trusted third-party service providers who perform technology services on our behalf (e.g., web hosting, chat providers, analytics services), but strictly for the purpose of carrying out their work for us. Contractors and service providers who may have access to Student Data in the course of performing their services are subject to confidentiality and data security requirements.
We may be required to share information with law enforcement or other third parties when compelled to do so by court order or other legal process, to comply with statutes or regulations, to enforce our Master Service Agreement, or if we believe in good faith that the disclosure is necessary to protect the rights, property or personal safety of our users.
We may use information in an aggregated and/or anonymous form that does not reasonably identify an individual or School. For example, we may use and share aggregate or anonymized data to study and improve our Service, user functionality, and product offerings.
If we sell, divest or transfer our business, we will not transfer personal information of our customers unless the new owner intends to maintain and provide the Service as a going concern, and provided that the new owner has agreed to data privacy standards no less stringent than our own. In such case we will provide you with notice and an opportunity to opt-out of the transfer of personally identifiable Student Data.
Accessing or Deleting a Child’s Personal Information
Upon written request, we will provide the School the opportunity to access and review the personal information collected from their students. At any time, a School can refuse to permit any further collection of a child’s personal information and/or request to delete a child’s personal information. If you are a Parent and you have questions about the personal information collected by Juego, please discuss your questions with your child’s School.
Please contact us at suport@gojuego.com if you believe we have inadvertently collected personal information of a child without proper consent so that we may delete such data as soon as possible.
6. LINKS TO OTHER WEB SITES AND SERVICES
We are not responsible for the practices employed by websites, applications or services linked to or from our Service. We recommend that the School review the privacy policies of other applications before authorizing a third party to access data through the Service.
7. HOW TO CONTACT US
If you have any questions about this Privacy Policy or the Service, we recommend contacting us:
By Email: support@gojuego.com
By Phone: (415) 322-8346
If you are not satisfied with our response, you can contact the iKeepSafe Safe Harbor Program’s dedicated consumer complaint department at: coppaprivacy@ikeepsafe.org
If a Student contacts Juego with a question about our Service, we will collect personal information from that Student only as necessary to respond to the Student’s request and direct the Student to contact the Student’s School, and we will then delete or anonymize the personal data of the Student after providing our response.
8. CHANGES TO OUR PRIVACY POLICY
Juego may modify or update this Privacy Policy from time to time so you should review this page periodically. If we change the policy in a material manner, for example, if we seek to use personal information in a materially different way than we had previously, we will provide at least 30 days’ notice. Of course, you can always opt-out by deleting your account before the changes take effect.
9. JURISDICTION-SPECIFIC DISCLOSURES
We may be required by law to provide additional privacy disclosures, depending on the jurisdiction in which you reside. Please refer below for disclosures that may be applicable to you: United States. If you are a resident of California, Colorado, Connecticut, Nevada, Utah or Virginia, please see below for additional privacy disclosures.
Additional Privacy Disclosures
For residents of California, Colorado, Connecticut, Nevada, Utah and Virginia: These Additional Privacy Disclosures for U.S. Residents (“U.S. Notice”) supplements the Juego Privacy Policy as well as any other agreement you may have with us. Any terms we use in this U.S. Notice that aren’t defined will have the meaning we provide in the Privacy Policy or other agreements.
For the purposes of this U.S. Notice, personal information does not include publicly available information or deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you. Additionally, this U.S. Notice does not apply to information relating to our employees, contractors, or other personnel.
A note about Student Data. Juego provides the Services to Schools as a “School Official” under FERPA. That means that we collect, retain, use and disclose Student Data only for or on behalf of a School customer for the purposes of providing the Services specified in our agreement with the School, and for no other commercial purpose. applicable state privacy laws, we collect, retain, use and disclose Student Data as a service provider or processor to our School customers and this U.S. Notice does not describe our practices with regard to Student Data or any other personal information we process as a service provider. If you have a question or would like to exercise your privacy rights available under FERPA or other applicable laws, please contact your School directly.
Collection and use of personal information. We collect personal information from and about you for a variety of purposes. For example, we use personal information to respond to your requests, engage with you as a customer, developer or other vendor, and provide our Services to you or receive Services from you; for marketing and advertising purposes; to monitor, improve, and develop our products and Services; and to protect the security and integrity of our business, comply with legal requirements and obligations; for our business and operational purposes; and as otherwise permitted or required by law.
The type of personal information we collect will depend on how you engage with us (for example, as a customer or potential customer, as a Developer, or as a website visitor). In the last 12 months, we have collected the following categories of personal information:
Identifiers, such as your name, address, phone number, email address, or other similar identifiers;
Customer records, such as payment information;
Professional and educational information, if you apply for a job with us through our website;
Commercial information, such as a history of our Services purchased, obtained or considered;
Internet/Network information, such as device information, logs and analytics data;
Geolocation data, such as precise location data from your device or generated based on your IP address; and
Inferences about your interests and preferences, generated from your use of our sites.
We collect this information directly from you, from our business partners and affiliates, from your browser or device when you visit our websites, or from third parties that you permit to share information with us.
Sensitive Information. Some of the categories of personal information described in our Privacy Notice may be classified as “sensitive” under certain U.S. state privacy laws (“sensitive information”), including payment card information or financial account number and routing number; and your username and password. We use this sensitive information for the purposes set forth in the How We Collect and Use Information section of our Privacy Policy to the extent necessary for the operation of our Services, to enter into and perform a contract with you, to comply with legal and regulatory requirements or as otherwise permissible for our own internal purposes consistent with law. Additionally, we may process sensitive personal information, such as information collected from a child or information about health or disability, in our role as a service provider on behalf of our customers.
Deidentified Information. We may process personal information to create deidentified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual. Where we maintain deidentified data, we will maintain and use the data in deidentified form and will not attempt to reidentify the data except as required or permitted by law.
Disclosure of Personal Information. We share personal information with third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt out of those sales (see Your Rights and Choices below). The categories of third parties to whom we disclose your personal information may include: (i) our service providers and advisors, (ii) vendors who assist us with marketing and advertising our services; (iii) analytics providers; (iv) third parties with your consent or at your direction, or with whom you interact through our Service.
When we disclose your personal information to our service providers, vendors or other third parties that process the information on our behalf, we have entered into a written contract that includes terms substantially similar to this notice and we will remain liable for any breach of this notice that is caused by the acts or omissions of our service providers.
Data Sales and Targeted Advertising. We do not sell personal information. However, on some adult-facing portions of our website we may allow third party partners to collect device and usage data for purposes of tracking adult visitors to our website for analytics, advertising, research and attribution purposes, which may be considered a “sale” under certain state data protection laws. You may be able to limit or opt-out of the sale of personal information or the processing of personal information for purposes of targeted advertising purposes (as described in the Your Rights and Choices section below).
Please note that we do not sell the personal information of consumers we know to be less than 16 years of age or use or share such information for targeted advertising purposes. We do not permit third party advertising networks to collect information about Student’s use of our products and we will never use Student Data for targeted advertising purposes.
Your Rights and Choices. Depending on your state of residence, you may be able to request to exercise the following rights:
The Right to Know whether we are processing any personal information about you and, under California law only, to obtain certain personalized details about the personal information we have collected about you, such as the categories and sources of such information, information about the third parties to whom we disclosed personal information and for what purposes.
The Right to Access the personal information we have collected about you and, where required by law and to the extent technically feasible, to obtain a copy of such personal information in a portable format.
The Right to Correct inaccuracies in your personal information.
The Right to Request Deletion of personal information we have collected from you, subject to certain exceptions.
The Right to Limit Use and Disclosure of Sensitive Information and exercise control over our collection and processing of certain sensitive information.
The Right to Opt Out of Personal Information Sales to third parties now or in the future.
The Right to Opt Out of Sharing Personal Information for Targeted Advertising based on your activity across businesses, websites, applications or services.
You also have the right to be free of retaliatory or discriminatory treatment for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.
To Submit your Privacy Rights Requests. You may submit a request to exercise your privacy rights through one of the mechanisms described below. We may need to verify your identity and state of residency before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.
To submit a request to exercise your privacy rights, please email us at support@gojuego.com.
To exercise your right to opt out of sales or targeted advertising, please email us at support@gojuego.com. Please note this opt out is browser specific. You must reset your preferences if you clear cookies or use a different browser or device.
Alternately, California users may call us by phone: (415) 322-8346
Authorized Agents. In certain circumstances, you may permit an authorized agent to submit requests on your behalf. The authorized agent must provide a letter signed by you confirming the agent has permission to submit a request on your behalf or must provide sufficient evidence to show that the authorized agent has been lawfully vested with power of attorney. For security purposes, we may need to verify your identity and confirm directly with you that you have provided the authorized agent permission to submit the request, and it may take additional time to fulfill agent-submitted requests. We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf. Please note that for privacy and security reasons, we will direct future communications to the data subject on whose behalf the request was made.
Appealing Privacy Rights Decisions. Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted via email to support@gojuego.com.
Changes to this U.S. Notice. Juego may modify or update this U.S. Notice from time to time so you should review this U.S. Notice periodically.