Breshna Privacy Policy

1 - Introduction and scope

Gaming Revolution for International Development Inc., doing business as Breshna ("Breshna," "we," "us," or "our"), provides a platform for creating, publishing, sharing, embedding and playing digital games. This Privacy Policy explains how we collect, use, disclose, retain and protect personal information when people visit breshna.io, create or use a Breshna account, create or play a game, interact with a game embedded in another service, or use Breshna through a school, organization or business partner (collectively, the "Services").

This Policy applies broadly to personal information processed through the Services, whether a person uses Breshna for personal, professional, commercial, entertainment, creative or educational purposes. Breshna may act as a controller or business for its own operations and as a service provider or processor when it handles information solely on another organization’s instructions.

This Privacy Policy does not apply to a third-party website, application or service that has its own privacy practices, even when it links to or embeds a Breshna game. When Breshna processes information for a School, employer, telecommunications provider, financial institution or other organization, that organization’s notice and agreement with Breshna may also apply.

Key definitions

• "Creator" means a person who uses Breshna to design, generate, upload, publish, manage or share a game or related content.
• "Player" means a person who accesses or interacts with a Breshna game, whether directly, through a shared link, or within another website or application.
• "Personal Information" means information that identifies, relates to, describes or can reasonably be linked with a person or household, as defined by applicable law.
• "Child" means a person under 13 for purposes of the United States Children’s Online Privacy Protection Act and may include older minors where another applicable law provides additional protection.
• "Education Services" means Breshna Services provided or authorized by a school for an educational purpose.
• "Parent" includes a parent or legal guardian.
• "School" means a school, school district, teacher acting with school authority, or other educational institution that authorizes the Education Services.
• "Student Data" means personal information relating to a student that Breshna receives from a School or collects through School-authorized use of the Education Services, including information that may form part of an education record.

2 - How people use Breshna

This Policy covers the different ways people and organizations interact with Breshna, including:

• Website visitors who explore Breshna’s website, public pages, demonstrations or game library.
• Creators who register for an account, create games, upload content, use AI-assisted features, manage a library or publish and share games.
• Players who access a game through Breshna, a shared link, an iframe, a microsite, a mobile application or a partner platform, whether or not they have a Breshna account.
• Subscribers and customers who purchase a plan, game, service or other offering.
• Business and distribution partners that integrate, sponsor, commission, host or distribute Breshna games.
• Teachers, Schools and students who use Breshna for classroom or other educational purposes.

Account holders must satisfy the minimum age stated in Breshna’s Terms of Use. Additional rules apply when a Child or student uses Breshna; those rules are explained in Sections 7 and 8.

3 - Information we collect

Information you or an organization provides

• Account information, such as name, email address, username, password credential or authentication token, organization, role and account preferences.
• Creator content, such as game text, questions, answers, images, audio, video, prompts, instructions, language, uploads and publishing settings.
• Profile and preference information, such as display name, profile image, saved games, settings and communication preferences.
• Communications and support information, including messages, feedback, survey responses and information submitted when reporting a problem.
• Transaction information, including subscription, purchase and billing records. Payment card details are processed by Breshna’s payment providers and are not intended to be stored by Breshna except as necessary for transaction records.
• Partner-provided information, such as a pseudonymous user identifier or entitlement status when a person reaches Breshna through an authorized partner platform.
• School and classroom information, where Education Services are used, such as a School-issued identifier, class or group assignment, teacher association, grade or age band, game assignment, progress, score and completion information.

Information collected through use of the Services

• Gameplay and activity information, including game identifier, session start and end, interactions, answers, score, progress, completion, feature use, referral page and error events.
• Device and network information, including IP address, approximate location derived from IP address, browser type, operating system, device type, language, time zone and diagnostic information.
• Cookie and similar technology information, including identifiers required for authentication, security, preferences, service operation and permitted analytics.
• Security information, including login activity, suspected abuse, fraud indicators, access logs and system events.

Sensitive information

Breshna does not ask users to submit sensitive information unless it is reasonably necessary for a specific feature or transaction and appropriate notice and safeguards are provided. Users should not place government identifiers, financial account credentials, precise geolocation, medical information or other unnecessary sensitive information in game content, prompts, public profiles or support messages. Additional collection limits apply to students and Children as described in Sections 7 and 8.

4 - How we use information

We use personal information only for the purposes described in this Policy, the notice presented when information is collected, or an applicable agreement. These purposes include:

• Providing, operating, authenticating, personalizing and supporting the Services.
• Creating, publishing, delivering and embedding games.
• Recording gameplay, progress, scores and completion when requested by a user, School or partner.
• Maintaining accounts, subscriptions and organization access.
• Processing transactions and sending service-related notices.
• Protecting the Services, investigating abuse, preventing fraud and maintaining availability.
• Diagnosing errors, measuring service performance and improving functionality.
• Analyzing aggregate trends to understand how the Services are used and to plan new features, game formats and content.
• Sending product news, offers, event invitations or other marketing communications where permitted by law and consistent with a user’s choices.
• Complying with law, enforcing agreements and protecting legal rights.

Product development and artificial intelligence

Breshna may use general service data, feedback and de-identified or aggregated usage information to test, maintain and improve its products. If Breshna uses a third-party artificial intelligence provider to process a user’s prompt or content, Breshna will disclose the relevant provider or category of provider and apply contractual and technical safeguards appropriate to the information. Users should not submit confidential or sensitive personal information to an AI-assisted feature unless the feature expressly supports that use.

Marketing communications

Breshna may use an adult account holder’s contact information to send information about Breshna products, services, events and offers where permitted by law. Recipients may unsubscribe using the link in the message or by contacting Breshna. Transactional, security and account-administration messages may continue even after a marketing opt-out. Breshna does not market products or services to students using Student Data.

5 - Cookies analytics and advertising

Breshna may use cookies, local storage and similar technologies that are necessary for authentication, security, user preferences and operation of the Services. Breshna may also use limited analytics to understand performance and feature use. Where required, nonessential technologies are activated only after consent.

Breshna does not permit advertising cookies, behavioral advertising pixels or cross-site tracking in Student-facing Education Services. Analytics used in those Services must be configured to collect only information reasonably necessary for the educational or operational purpose, must not use Student Data for advertising, and must be subject to Breshna’s contractual controls.

6 - How we disclose information

Breshna may disclose personal information only as described below:

• To service providers that perform hosting, infrastructure, authentication, analytics, communications, customer support, payment processing, security or other functions for Breshna under contractual restrictions.
• To a School, teacher or administrator in connection with the School-authorized Education Services, including student progress and activity information.
• To an authorized business partner when necessary to deliver an integration, entitlement, game or service requested through that partner.
• At the user’s direction, including when a creator publishes a game or intentionally shares content publicly.
• To professional advisers and auditors subject to appropriate confidentiality obligations.
• To law enforcement, regulators, courts or other parties when Breshna reasonably believes disclosure is required by law or necessary to protect rights, safety, security or the integrity of the Services.
• In connection with a merger, financing, acquisition, reorganization, bankruptcy or sale of assets, subject to appropriate confidentiality protections and continued limits applicable to Student Data.

Breshna does not sell personal information. Breshna does not disclose Student Data for third-party marketing or targeted advertising.

7 - Schools and FERPA

The Family Educational Rights and Privacy Act (FERPA) applies to certain United States educational institutions and protects personally identifiable information from education records. FERPA does not create a general certification issued to technology vendors. Breshna supports Schools’ FERPA obligations through product controls and contractual commitments.

When a School discloses education-record information to Breshna under FERPA’s school official exception, Breshna will:

• perform the institutional service or function specified by the School;
• remain under the School’s direct control regarding the use and maintenance of the education-record information;
• use the information only for the purpose for which the School disclosed it;
• limit access to personnel and service providers with a legitimate need to perform the authorized service;
• not redisclose the information except as permitted by the School, the applicable agreement and FERPA;
• assist the School with access, correction, export and deletion requests; and
• return or securely delete the information at the School’s direction or at the end of the service relationship, subject to applicable law and the retention schedule below.

Breshna uses Student Data solely to provide, maintain, secure and improve the School-authorized Education Services, follow the School’s lawful instructions and comply with law. Breshna does not sell or rent Student Data; use it for targeted or behavioral advertising; market products to students; build unrelated commercial profiles; or use it to train a general-purpose artificial intelligence model. Breshna does not require students to provide more information than is reasonably necessary for a School-authorized activity.

Breshna may use information that has been de-identified so that it cannot reasonably identify a student, provided Breshna maintains safeguards against re-identification and does not use the information for targeted advertising to students.

Breshna’s School Data Privacy Agreement provides additional terms governing Student Data, security, incident notification, service providers and deletion. If there is a conflict between this Policy and a School agreement concerning Student Data, the more protective applicable term will control to the extent permitted by law.

8 - Children under 13 and COPPA

The Children’s Online Privacy Protection Act (COPPA) applies to operators of websites or online services directed to Children and to operators with actual knowledge that they collect personal information online from a Child. Personal information under COPPA can include persistent identifiers and other technical information, even when a Child does not provide a name or email address.

Anonymous play

Where Breshna permits a Child to play without an account, Breshna limits collection to information reasonably necessary to provide the activity, maintain security and support permitted internal operations. Breshna does not condition participation on disclosure of more information than is reasonably necessary. Breshna does not use information collected from a Child for targeted advertising, third-party marketing or unrelated profiling.

School-authorized use

A School may authorize Breshna’s collection of a Child’s personal information on behalf of a Parent only where permitted by COPPA and only for the use and benefit of the School and for no other commercial purpose. Before relying on School authorization, Breshna provides the School with notice of its collection, use, disclosure, retention and security practices and obtains documented authorization from an appropriate School representative. Breshna remains responsible for its own COPPA obligations and does not require a teacher or School to assume those obligations on Breshna’s behalf.

Parental consent

When School authorization is unavailable or insufficient and COPPA requires consent, Breshna will provide direct notice to the Parent and obtain verifiable parental consent before collecting, using or disclosing the Child’s personal information, unless a COPPA exception applies. A Parent may refuse further collection, request access to the Child’s personal information, request correction or deletion, and withdraw consent by contacting [email protected] . Breshna will verify the requester’s identity before granting access or deletion.

Collection without authorization

If Breshna learns that it collected personal information from a Child in a manner requiring consent or School authorization and did not obtain it, Breshna will stop the unauthorized processing and delete the information in accordance with law. A Parent or School that believes Breshna may hold unauthorized information about a Child should contact [email protected].

9 - Data retention and deletion

Breshna retains personal information only for as long as reasonably necessary for the purpose for which it was collected, to follow a School’s lawful instructions, to provide the Services, or to meet legal, accounting, security and dispute-resolution obligations. Breshna applies the following maximum periods unless law or a contract requires a shorter period, or a documented security incident or legal hold requires limited preservation:

Deletion from active systems may occur sooner. Secure backups are isolated from ordinary use and expire through Breshna’s backup cycle. When immediate deletion from a backup is not technically feasible, Breshna will prevent further processing except for restoration, security or legal necessity and will delete the information when the backup expires.

10 - Security and incident response

Breshna maintains reasonable administrative, technical and organizational safeguards designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. The safeguards are proportionate to the nature of the information and include, as appropriate, encryption in transit and at rest, access controls based on job responsibilities, authentication controls, logging and monitoring, secure development practices, vulnerability management, backups, employee confidentiality obligations, service-provider review and incident-response procedures.

No online service can guarantee absolute security. If Breshna discovers a security incident affecting personal information, Breshna will investigate, contain and remediate it and will notify affected Schools, users, Parents and regulators as required by law and applicable agreements.

11 - Access correction deletion and control

Depending on the relationship and applicable law, a person may request access to, correction of, deletion of, restriction of, objection to processing of, or a portable copy of personal information. A person may also withdraw consent where processing relies on consent and may opt out of nonessential marketing communications.

Account holders may use available account controls or contact [email protected]. Parents may submit requests concerning a Child as described in Section 8. Students and Parents seeking access to Student Data controlled by a School should contact the School first; Breshna will assist the School in responding. Breshna may take reasonable steps to verify identity and authority before fulfilling a request.

A request may be limited or declined where permitted by law, including where Breshna cannot verify the requester, must protect another person’s rights, must retain information to comply with law, or the request concerns information controlled by a School and requires the School’s instruction.

12 - Public content and sharing

A creator may choose to publish a game or other content publicly. Public content can be viewed, copied, shared or indexed by others. Creators should not include personal information about a student or Child in publicly available game content. Schools and teachers are responsible for reviewing content and publishing settings before assigning or publishing a game. Breshna may provide privacy-protective defaults for Education Services, including restricted or unlisted sharing.

13 - International processing and transfers

Breshna is headquartered in the United States and may process information in the United States and other countries where Breshna or its service providers operate. Those countries may have different data-protection laws. Where required, Breshna uses appropriate safeguards for international transfers, such as approved contractual clauses, adequacy mechanisms or another lawful transfer mechanism.

14 - Additional regional rights

European Economic Area United Kingdom and Switzerland

Where applicable, Breshna processes personal information under one or more lawful bases, including performance of a contract, legitimate interests that are not overridden by individual rights, compliance with legal obligations, consent, and protection of vital interests. Individuals may have rights to access, rectify, erase, restrict or object to processing, receive a portable copy, withdraw consent and complain to a supervisory authority. Contact [email protected] to exercise a right.

United States state privacy rights

Residents of certain United States states may have additional rights, subject to exceptions, including rights to know, access, correct or delete personal information and to opt out of certain sales, sharing, targeted advertising or profiling. Breshna does not sell personal information and does not use Student Data for targeted advertising. Requests may be submitted to [email protected]. Breshna will not unlawfully discriminate against a person for exercising a privacy right. An authorized agent may submit a request where permitted by law, subject to verification.

15 - Service providers and business changes

Breshna requires service providers that process personal information on its behalf to protect the information, process it only for authorized purposes and comply with applicable contractual and legal requirements. Before a new service provider is permitted to process Student Data or Child personal information, Breshna assesses the provider and imposes appropriate restrictions.

If Breshna undergoes a merger, acquisition, restructuring, financing, bankruptcy or sale of assets, personal information may be transferred as part of that transaction. Student Data and Child personal information will remain subject to applicable legal and contractual restrictions, and Breshna will provide notice where required.

16 - Changes to this Policy

Breshna may update this Policy to reflect changes in the Services, practices or law. Breshna will post the revised Policy with a new effective date. If a change materially affects the collection, use or disclosure of Student Data or Child personal information, Breshna will provide additional notice to affected Schools or Parents and obtain new authorization or consent where required before applying the change to previously collected information.

17 - Contact Breshna

Questions, privacy requests and concerns may be directed to:

Gaming Revolution for International Development Inc.

Email: [email protected]
Website: https://breshna.io