In-Game Learning Privacy Policy

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Effective Date: November 3, 2025

Responsibility: CEO

Purpose:

In-Game Learning Pty Ltd (In-Game Learning, we, us) values and respects the privacy of the people we deal with. We are committed to protecting your privacy and complying with the law. In particular, we comply with these laws:

Australian Privacy Principles under the Privacy Act 1988 (Cth) (Australian Privacy Act)
the General Data Protection Regulation (EU) 2016/679 (EU GDPR); and
the GDPR as it applies to the UK under UK law (UK GDPR).

This Privacy Policy (Policy) describes how we collect, hold, use and disclose your personal information, and how we maintain the quality and security of your personal information.

What is personal information?

“Personal information” is defined in the Australian Privacy Act to mean information or an opinion about an identified individual, or about an individual who is reasonably identifiable. The definition covers information regardless of these 2 considerations:

Whether the information or opinion is true or not.
Whether the information or opinion is recorded in a material form or not.

In this Policy, whenever we use the term “personal information”, we are referring to this legal definition.

Personal information does not include:

aggregated or de-identified data
electronic identifiers such as IP address, mobile device UDID and IMEI numbers, operating system, browser type, and screen size.

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What personal information do we collect?

The personal information we collect about you depends on the nature of your dealings with us or what you choose to share with us.

The personal information we collect about you may include your:

name
mailing or street address
date of birth
email address
phone number
organisation
position.

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You are not obliged to provide us with personal information, but if you do not, then we may not able to provide you with our services. If possible, we will give you the option to interact with us anonymously or by using a pseudonym. However, we may not be able to provide you with our services if we cannot identify you.

How do we collect your personal information?

We collect your personal information directly from you when you:

interact with us over the phone
interact with us in person
interact with us online
play our games
participate in surveys or questionnaires
attend an In-Game Learning event
subscribe to our mailing list or free trial lists
apply for a position with us as an employee, contractor, volunteer, or for work experience.

Collecting personal information from third parties

We may also collect your personal information in either of these ways:

From third parties. For example, if your employer has arranged for you to play any of our games, then we may collect your personal information from your employer.
Through publicly available sources.

We collect your personal information from your employers so that we can provide your employer with learning and development outcomes.

How do we use your personal information?

We use personal information for many purposes in connection with our functions and activities, including the following purposes:

providing you with our products
delivering to you a more personalized experience and product
improving the quality of the services we offer
performing internal administrative purposes
marketing and research purposes.

Disclosure of personal information to third parties

We may disclose your personal information to third parties in any one or more of these ways:

For the reasons for which we collect, store and use that information (see above).
If your employer has arranged for you to play any of our games, then we may share your personal information with your employer.
For other purposes explained at the time we collect your personal information.
If the law otherwise allows us, or requires us to do so.

For example, we may disclose your personal information to any one, or more, of these people:

your employer
our IT providers
our marketing providers
our sales advisors
our related entities
our professional advisors, consultants, etc.
our insurance providers and financial institutions
to regulatory bodies if the law allows us, or requires us, to do so.

Transfer of personal information overseas

We store personal information in data centers in Australia, the United States, France and Spain. We will take reasonable steps to ensure your personal information is treated securely and in accordance with a law or binding scheme that is, overall, substantially similar to the Australian Privacy Principles.

There are other circumstances where we may disclose your personal information to an overseas recipient. For example, if you have consented to us doing so, or the law allows us, or requires us, to do so.

How do we protect your personal information?

We will take reasonable steps to ensure that the personal information that we hold about you is kept confidential and secure, including by doing the following things:

Having a robust physical security of our databases and records.
Taking measures to restrict access only to personnel who need that personal information to effectively provide products and services to you.
Having technological measures in place (for example, anti-virus software, fire walls).

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European Economic Area and UK Privacy Terms

If you are an individual who accesses our services in the European Economic Area (EEA), then this Policy does not limit or exclude any rights that you have or may have under the EU GDPR. Similarly, if you are an individual who access our services in the UK, then this Policy does not limit or exclude any rights that you have or may have under the UK GDPR. Our obligations under the EU GDPR and UK GDPR apply only where, and to the extent, these laws apply.

In-Game Learning is the data controller for the purposes of the EU GDPR and UK GDPR.

When we may process your data

If either the EU GDPR or UK GDPR applies to you, then we may process your personal data using any one, or more, of the following legal bases:

Performance of a contract: If we need to do so for either of these reasons:
- To perform a contract that we are about to enter into, or have entered into, with you.
- To take steps, at your request, before entering into a contract with you.
Legal obligation: The processing is necessary for us to comply with our legal obligations.
Legitimate interests: The processing is necessary for our (or a third party’s) legitimate interests.
Consent: You have given your express consent to us processing your information for these specific reasons.

If either the EU GDPR or UK GDPR applies to you and we process sensitive or special category personal data, then we will also ensure the law allows us to do so. We rely on any one, or more, of the following conditions to do so:

We have your explicit consent.
The processing is necessary for us to comply with our obligations as an employer.
The processing is necessary for reasons of substantial public interests.
The processing is necessary to protect your (or someone else’s) vital interests, but you are physically or legally incapable of giving consent.
The processing is necessary to establish, exercise or defend legal claims.

Transferring data outside the EEA

If we transfer personal data outside of the EEA, then we ensure that at least one of the following safeguards is implemented:

We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the EU Commission.
We may enter into standard contractual clauses (or equivalent measures) with the third parties located outside of the EEA.
We may transfer your personal information outside the EEA if you explicitly consent.

How you may complain

If either the EU GDPR or UK GDPR applies to you, then you can file a complaint about us with either, or both, of the regulator or the data protection authority in your jurisdiction. You may do so if either, or both, of the following is the case:

You are not satisfied with our response to your complaint.
You believe that we have breached applicable laws and regulations with regards to the handling of your personal data.

Your rights about your data

If either the EU GDPR or UK GDPR applies to you, then you have the following rights in relation to your personal data (where applicable):

Right to Access: You have the right to request access to, or copies (and transmission) of, the Personal Information we hold about you and the purposes for which we are using it.
Right to Rectify: You have the right to correct inaccurate Personal Information that we have collected from and maintain about you, subject to appropriate verification.
Right to Erase: You have the right to erase Personal Information relating to you, under certain conditions. If you ask us to erase your Personal Information, then we will first seek to verify your identity. We will let you know if we need additional time.
Right to Object: You have the right to object to us processing your Personal Information we process about you, under certain conditions.
Right to Restrict: You have the right to restrict the processing of your Personal Information, under certain conditions.
Right to Data Portability: You have the right to receive the data we have collected from you. Under certain conditions, you may request that we transfer your Personal Information to another organisation, or directly to you.
Right to Lodge a Complaint: You have the right to file a complaint with the supervisory authority in your jurisdiction, see above.

When you exercise any of these rights, we will respond within a reasonable period and in any event within one month (as the EU GDPR or UK GDPR requires). However, in some circumstances, the EU GDPR or UK GDPR allows us to extend the period within which we respond to your rights request by up to 2 months.

If you have consented to us processing your personal information, then you have the right to withdraw that consent, at any time. Even if you withdraw your consent, we may still be able to process your personal information in either, or both, of these cases:

The law allows, or requires, us to do so.
For the purpose of exercising or defending our legal rights.

To ask us to exercise any of these rights in relation to your personal data, please contact us using the relevant contact details set out below.

Online activity

Cookies

The In-Game Learning website uses cookies. A cookie is a small file of letters and numbers that our website puts on your device if you allow it. These cookies recognise when your device has visited our website(s) before, so we can distinguish you from other users of the website. This improves your experience of our website(s) and game(s).

We do not use cookies to identify you, just to improve your experience on our website(s) and game(s). If you do not wish to use the cookies, then you can amend the settings on your internet browser so it will not automatically download cookies. However, if you remove or block cookies on your computer, then your browsing experience and our website’s functionality may not be as good as it would be with cookies.

Analytics

Some of the third-party services that we use to monitor and analyse web traffic and user behaviour include:

Google Analytics – We use Google Analytics to help us better understand traffic (add, organic and paid) to and from our site.
Segment – We use Segment to collect and control customer interaction information.
Mixpanel – We use Mixpanel to better understand the data generated from the use of our site.

Although this data is mostly anonymous, it is possible that, we may connect it to you. If that happens, then information will be handled as this Policy requires.

Direct marketing

We may send you direct marketing communications and information about our services, opportunities, or events that we consider may be of interest to you. However, we will do this only if you have either requested, or consented to receive, these communications. We may send these communications in various forms, including mail, SMS, and email, in accordance with the law, for example the Australian Spam Act 2003 (Cth). If you indicate a preference for a method of communication, then we will endeavor to use that method whenever practical.

You may opt-out of receiving marketing communications from us at any time by following the instructions to “unsubscribe'' set out in the relevant communication.

Links to third party sites

In-Game Learning’s website(s) may contain links to websites operated by third parties. If you access a third party website through our website(s), then that third party website may collect your personal information. We make no representations or warranties in relation to the privacy practices of any third party provider or website. We are not responsible for the privacy policies or the content of any third party provider or website.

Any third party providers / websites are responsible for informing you about their own privacy practices and we encourage you to read their privacy policies.

Keeping personal information

We will not keep your personal information for longer than we need to. In most cases, this means that we will only keep your personal information for the length of your relationship with us. However, we may keep it for longer if we need to do so to comply with the law, for example record-keeping obligations.

How to access and correct your personal information

In-Game Learning will endeavour to keep your personal information accurate, complete and up to date.

If you wish to access or correct the personal information we hold about you, then please contact us. We will usually respond within 7 business days in Melbourne, Australia. We will not charge any fee for your access request. But we may charge an administrative fee for providing a copy of your Personal Information.

We may decline your request to access or correct your information in certain circumstances in accordance with the law. If we do decline your request, then we will provide you with a reason for our decision. Also, if we decline your request to correct information, then we will include a statement about your request with the personal information we store about you.

Inquiries and complaints

For complaints about how In-Game Learning handles, processes or manages your personal information, please contact the Chief Operations Officer. If you do that, then before we process your inquiry or complaint, we may require proof of your identity and full details of your request.

We will not always be able to resolve a complaint to everyone’s satisfaction. If you are not satisfied with In-Game Learning’s response to a complaint, then you have the right to contact the Office of Australian Information Commissioner (at www.oaic.gov.au/) to lodge a complaint.

How to contact us

If you have a question or concern in relation to our handling of your personal information or this Policy, then you can contact us for assistance as follows:

Email

ceo@ingamelearning.com

Contact number

+61 480839533

Post

Attention:

COO

In-Game Learning Pty Ltd

C/Smith Feutrill

Unit 2

801Glenferrie Road

Hawthorn, VIC 3122

Questions

For questions about this policy, contact the Chief Operations Officer.

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