We at TherapyPath (“TherapyPath”, “we”, “us” or “our”) respect your privacy and recognize the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process your personal data.

We and our partners store and/or access information on a device, such as email you provided us with and/or cookies to process personal data. By using our service, you accept or if necessary, you can send us an email for your right to object where legitimate interest is used, or at any time in the privacy policy page. These choices will be signaled to our partners and will not affect browsing data.

About Your Privacy

The purpose of this privacy notice (“Privacy Notice”) is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you, “Personal Data”) when you visit the testing website that are part of our testing platform. This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing.

In this Privacy Notice, we will give you general information about how we process your Personal Data. We will furthermore give you more detailed information on the processes within our Services.

General Information

In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you access or play a game from one of our testing Websites. For specific information with more details about our processing activities on the respective testing Website, please see the service specific information below.

Who is Responsible for the Process of Your Personal Data

Therapypal, UK ("the data controller") for the processing of your Personal Data.

You can reach our data protection officer under tc@therapy-palth.com

What Types of Personal Data Do We Process and How do We Collect It?

As a general principle, we do not collect and do not ask you to provide any "special categories of Personal Data", which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation.

Data:

Personal Data provided by you

You can visit and take our tests without registering or logging into our website. When you access our Website, you provide or be asked to give us certain information, including:

Data provided in relation to our customer service: When you contact support, we collect information about your request (subject and content of your request) and your contact details (e-mail address).

*Your account information: On our Website, you have the option to sign up for an account. If you choose to create an account, we collect your log-in data (your email address and password).

Personal Data we receive or generate from your use of our Services

FOR WHAT PURPOSE DO WE PROCESS YOUR DATA?

We may process your Personal Data for the following purposes:

Provision and improvement of our Tests and services to allow you to play our Tests, including third-party Tests available on our testing Websites

to create and manage your account

to communicate with you in context of account activation, password management

to simplify the registration process

to provide technical support and respond to your requests

to help you set up a Therapy you decided

to indicate the best results for your Test

to assess the quality of our services and improve

to recommend future Tests you may take based on your progress

to personalize advertising for you

to remember you next time you visit one of our testing Website

Marketing and analytics

to deliver (targeted and non-targeted) advertising in our Tests or on our testing Websites

to measure the effectiveness of advertising

to send you marketing communications, informing your about new content and in-game offers

to understand usage of our Services across all our group companies to support strategy and growth

Prevention of fraud and illegal activity

to investigate fraud and illegal behaviour on our testing Website and reporting it to relevant authorities

to enforce our policies and terms of use

Compliance with our legal or regulatory obligations

to determine the legal requirements for processing of your Personal Data (based on your location and your age)

to obtain a valid (parental) consent, if necessary

to respond to your requests related to your data subject rights to comply with our legal obligations (e.g. tax and accounting obligations)

to inform you about any changes to this Privacy Notice

Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data per testing Website.

XXXXXXX

Third-party game Distributors: On our testing Websites, we offer Tests from third-party game distributors. By playing a third-party game, your Personal Data will be processed by the third-party game distributors (directly or through the use of cookies or similar technology). Please note that by choosing a third-party game, you will be able to play the game in the third-party game developer's environment over which we have no control. We only receive anonymized statistics and revenue reports from third-party game distributors. We therefore advise you to check the privacy policies of any such game distributor before starting the game. Furthermore, you can find the third parties your Personal Data may be processed by playing our Tests or testing Websites in the following link: 3rd Party list.

advertising companies: With your consent, we share your Personal Data with third-party advertising companies or allow third-party advertising companies to collect your Personal Data when you access or play a game from our testing Website. If you choose not to receive personalised ads at all, we will still show you ads, but they may not reflect your interests as those ads will be content specific and not user specific. Please note that by clicking on a third-party advertisement, you will be redirected to the third-party advertiser's environment over which we have no control.

Law enforcement, government authorities or courts: We disclose your Personal Data in response to lawful requests to public authorities, including law enforcement, government authorities, or courts. We may also disclose your Personal Data to legal authorities where we believe such disclosure is necessary for prevention of a crime, facilitation of an investigation related to public safety, protect the security or integrity of our Service, or enable us to take precautions against liability or to protect our rights.

Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).

Please see the section with service specific information below for more information about the third parties we may share your data with.

How Do We Protect Minors?

The data we collect from minors and our communication with parents

We offer our users a range of Tests Website. Some of our Tests might be used by minors if there is no Parental Firewall. When we refer to minors, we mean persons under the age of 16. Protecting the privacy of minors is extremely important to us. When you identify yourself as being a minor, we generally do not process your Personal Data. However, we process your Personal Data in the following potential instances:

Entering testing Website: For our testing Websites until you have to pay. So no information is guarded from a Minor. While your Personal Data, in general, also be processed by using cookies when you visit those Tests or testing Websites, no cookies except for strictly necessary ones (as described below) are used when you indicate being under the age of 16.

When you register to one of our testing Websites, with our single sign on authentication you will be asked to confirm your age (day, month and year of birth). For this age-confirmation method, we will also collect your geolocation data for presenting the age-gate in the correct language. Your date of birth and geolocation data will only be used to verify your age and will not be stored.

GDPR

In general, your data is stored on servers within the European Union (EU) / the European Economic Area (EEA). However, your data may also be shared outside the EU / EEA. We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission's Standard Contractual Clauses (also known as Model Clauses) to provide safeguards for your Personal Data.

Protecting Your Personal Data

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.

How Long Do We Store Your Personal Data?

We will not retain your Personal Data longer than necessary to fulfil the purposes for which the data was collected or to fulfil our legal obligations. Afterwards, we will delete or anonymize your Personal Data. Please see below for game specific information about how long we will retain your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available here.

What Are Your Rights?

To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:

Access the Personal Data we hold about you, including information such as, for example, the source and the categories of the data, the purposes of the processing, the recipients (or categories thereof) and the respective retention period.

Request the update or correction of your Personal Data so that it is always accurate.

Receive your Personal Data in a structured, commonly used and machine-readable format, including the right to transmit your Personal Data to another controller.

Request the deletion of your Personal Data if you think that it is no longer needed for the purposes indicated above. To submit this request, contact our support team or our Data Protection Officer.

Restrict the processing of your Personal Data in certain circumstances, for example, where you have contested the accuracy of your Personal Data, for the period enabling us to verify its accuracy.

Withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the lawfulness of the processing based on consent before its withdrawal.

Right to object

In the event and to the extent that we process your Personal Data based on our legitimate interest, you have the right to object to the processing on specific grounds relating to your particular situation. In such case we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishments, exercise or defence of legal claims.

You also have the right to object where we are processing your Personal Data for direct marketing purposes (including profiling). In such case, we will stop processing your Personal Data for marketing purposes.

You can exercise these rights by sending a request to the contact details set out below, providing your name, your email address as well as a description of your request.

If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example, the Autoriteit Persoonsgegevens in the Netherlands.

How to Contact Us?

If you have any queries about this Privacy Notice or how we use your Personal Data, please contact our Data Protection Officer via e-mail to tc@Therapy-Path.com.

HOW OFTEN DO WE UPDATE THIS PRIVACY NOTICE?

We regularly review this Privacy Notice. When there is an important change that will have a relevant impact on the processing of your Personal Data, we will inform you by email if we have your email address. If we do not have your email address, for example because you did not create an account, we will inform you with a banner on our testing Website.

This Privacy Notice was last updated on:

Version

Last updated

1.01

December 13, 2023

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

This section for California residents supplements the information provided in this Privacy Notice and applies solely to players, and others who reside in the State of California. We provide this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and the regulations issued under it; accordingly, this section addresses the specific requirements of the CCPA and should be read together with this Privacy Notice.

We do not sell your Personal Data. However, we may share or provide access to each of the categories of Personal Data we collect as necessary for our business purposes. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, we have collected the following categories of personal information (envisaged by the CCPA) from consumers within the last twelve (12) months:

Category A – Identifiers (such as your device identifier, demographic information -such as your country, your username, email address, any information you may choose to provide -such as your age or your language-)

Category B- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Category D – Commercial information (such as purchase history)

Category F – Internet or other similar network activity (such as your interaction with our ads, your IP address)

Category G – Geolocation data

The CCPA provides consumers (California residents) with specific rights regarding their personal information.

You have the right to access specific information i.e. you may request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.

You have the right to know. Under the CCPA you have the right to request that we disclose to you what Personal Data we process about you.

You have the right to deletion which means that you may request that we delete any of your personal information we collected from you and retained, subject to certain exceptions.

You have the right to data portability which enables you to request to transfer your personal data to another data controller.

Under the CCPA, you have the right to opt out of any sale of your personal data. Please note that your right to opt out does not apply to our sharing of personal data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal data only for that function.

Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.

You can exercise these rights by sending a request to the contact details set out above, providing your name, your email address as well as a description of your request.

ADDITIONAL INFORMATION FOR BRAZIL RESIDENTS

Under the Brazilian General Data Protection Law (the "LGPD"), you have the right to access, rectify, port, erase, and confirm that we process your data. If you have given consent about processing your data, you have the right to withdraw consent anytime.

SERVICE SPECIFIC INFORMATION

In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed in our Website. For general information about data processes that apply to Tests and Website, please see above.

Account: On our testing Website, you have the option to sign up for an account. If you choose to create an account, we collect your log-in data (your email address, date of birth, name, surname and password). For some of our testing Websites, we use a single sign-on solution called TherapyPath Connect and when you create an account on those testing Websites, you create an TherapyPath Connect account.

Hosting and content delivery: testing Websites are hosted by external companies providing web servers and web content delivery. Every time you make a request, for example by clicking on a link on our platform, the information allowing this request (e.g. device information and information on requested content) will be sent to the external servers. This data is used to show you the content you requested in a faster way. We process this data on the basis of our legitimate interest, to provide and improve our service and ensure its functionality.

Customer service: If you contact us for customer support by using our email address, an external customer service company will process your email address, and the content of your request in order to provide you with support. The request history helps us to solve a newer request and is stored to defend possible future legal claims. We process this data on the basis of performance of a contract to provide you with customer support, and store this data on the basis of our legitimate interest, to improve our services, and to be able to defend possible future legal claims.

Comments: If you register to our testing Websites, you have the option to comment on the Tests and profiles of other users. We process your username and timestamp to recommend Tests and improve the community.

Analytics: We use web and social media analytics companies to understand how popular our Tests are on social media and to monitor traffic on testing Websites, for example following changes to the website. For this purpose, we process information about your device, request data (including the URL of the current webpage and the website visited before) and special event data (for example if you share a link with your friends in the social media platform). We also process your full IP address to allow us to better understand how you use our Tests or our website and to improve our Tests and websites. We process this information based on your consent, provided in the consent pop-up which will be shown to you when you access testing Websites for the first time. We also process your IP address and user id to determine the number of unique users of our Services within our group companies. We process your personal data in connection with this activity based on legitimate interest.

We shall only use this information for identification purposes and contract processing. For more information on Facebook Connect and the privacy settings, please refer to the Privacy Policy and Terms of Use of Facebook Inc.

https://www.facebook.com/policy.php.

Google

Our web presence also employs the Google link, which is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (Google). The link can be identified by the "Google" symbol against a white or color background.

If the user opens one of our websites containing such a link, the user's browser establishes a direct connection to a Google server. The contents of the "Google" link are transferred directly to your browser, which then integrates said content in the webpage. We therefore have no control over the data whatsoever that Google collects via the link, but would expect user IP addresses to be collected.

The purpose and scope of data collection via Google, the processing and use of such data, as well as your rights thereof and personal settings regarding privacy protection can be found in the Google privacy settings section https://policies.google.com/privacy?hl=en-US

If a user is a Google member and does not wish to have their data collected and linked to their saved Google member data via our web presence, the user must log out of their Google Plus account before visiting our websites.

Youtube

TherapyPath publishes posts/videos on TherapyPath's fan pages on Youtube. These posts/videos contain links to the main TherapyPath domain (e.g. a video of a game on Youtube, which has a link directing to that game in the TherapyPath portal.)

Advertising: On testing Websites, we show advertising from different advertising companies. These adverts can be personalized or non-personal content related ads. In order to show you personalized ads and only if you have provided your consent, we will share your Personal Data (your IP address, advertising identifiers and the information that you have provided your consent for personalized ads) through our advertising platform provider with third-party advertisers and ad networks. We also use this information to measure how effective these ads are. In our consent pop-up which will be shown to you the first time you enter our testing Website, you can choose from which advertising company you would like to receive personalised ads or choose not to accept receiving personalised ads at all. You can adjust your preferences at any time in your privacy settings. If you choose not to receive personalised ads at all, we will still show you ads, but they may not reflect your interests as those ads will be content specific and not user specific.

Data management platform: Based on your consent, we process your Personal Data to show you relevant Tests and ads, based on the information about the Tests you are playing on testing Websites. For this purpose, your device information, IP address and information about the category of the game you played is collected and sent to an external data management platform provider.

Rating function: You can rate the Tests on testing Websites, by choosing a thumbs up or thumbs down icon. It is in our legitimate interest to provide our users an overview which Tests are most popular and best rated. When you click on a rating button, we will store the aggregated voting data. The result of all the submitted ratings is used to generate a score between 1 and 5 for each game. In addition, a local text file will be stored to prevent multiple ratings for the same game. We will store this data in your browser's local storage and we will not share this data with other partners.