Privacy Policy

Last Updated: July 14, 2026

This Privacy Policy explains how Gamena ("Gamena", "we", "us", or "our") handles personal data when you use our websites, educational applications, games, and related services (the "Services"). It also explains the choices and rights available to individuals, including rights under the EU and UK General Data Protection Regulation (GDPR).

1. Our Role and Scope

Gamena generally acts as a data controller for website visitors, account holders, billing contacts, and people who contact us. When a school, teacher, or other educational organization uses Gamena with students, that organization ordinarily determines why and how student data is used and acts as the controller; Gamena processes that data on its instructions as a processor or service provider. A data processing agreement is available to eligible educational customers.

2. Information We Collect

We collect data that you provide, data generated through use of the Services, and limited technical data needed to operate and secure the platform.

• Account and organization data: name, email address, telephone number, account credentials, role, school or organization, and preferences.
• Student data: a nickname or name, class membership, exercise responses, scores, progress, and related learning records configured by the responsible educator or school. We ask customers to avoid entering data that is not needed for learning.
• Content: exercises, text, images, documents, questions, and other material submitted to or created with the Services.
• Transactions and communications: subscription, invoice and payment status information, support requests, survey responses, and messages. Full payment-card details are handled by our payment provider rather than stored by Gamena.
• Technical and usage data: IP address, browser and device information, timestamps, diagnostic logs, security events, and interactions with the Services.

3. Purposes and Legal Bases

Where GDPR applies, we process personal data only when a legal basis is available. Depending on the context, we use data to:

• provide accounts, games, learning features, support, and subscriptions as necessary to perform a contract;
• secure, troubleshoot, and improve the Services, prevent misuse, and understand aggregate usage based on our legitimate interests, balanced against individual rights;
• meet tax, accounting, child-safety, and lawful disclosure obligations;
• send optional marketing or use non-essential cookies with consent where consent is required; and
• process student data on the documented instructions of the relevant school or educator.

4. Children and Educational Records

Gamena is designed for educator-, school-, or parent-directed use. Schools and educators are responsible for providing required notices and obtaining any consent or other authorization needed before submitting student data. We process student data only to provide and support the educational service, do not sell it, and do not use it for targeted advertising. Customers subject to FERPA, COPPA, GDPR, UK GDPR, or similar student-privacy laws must configure and use the Services consistently with their own obligations. A child should not independently create an adult or educator account.

5. Sharing and Service Providers

We do not sell personal data. We disclose only what is reasonably necessary:

• to vetted providers supporting hosting, storage, communications, security, payments, support, and AI functionality under contractual confidentiality and data-protection duties;
• to the school or organization that manages an account and to users authorized by that organization;
• when required by law, legal process, or a valid government request, or when necessary to protect rights, safety, and platform security;
• in connection with a merger, financing, reorganization, or sale, subject to appropriate safeguards; or
• with the individual's or controller's direction or consent.

6. Artificial Intelligence

Content submitted to AI features may be sent to contracted AI providers to generate the requested output and support safety and reliability. Gamena does not use customer educational content to train public AI models. Do not submit sensitive personal data or confidential material unless it is necessary, authorized, and permitted by your organization's policies. AI output may be inaccurate and should be reviewed by an educator before use.

7. Retention

We retain personal data only for as long as needed to provide the Services, fulfill the purposes described above, comply with legal and accounting duties, resolve disputes, and protect the Services. Retention periods depend on the type of data and customer instructions. When an account or school contract ends, data is deleted or de-identified according to the applicable agreement and backup lifecycle, unless law requires longer retention.

8. International Transfers

Providers and users may process data outside the country where it was collected. Where GDPR or UK GDPR requires it, we use an approved transfer mechanism, such as an adequacy decision or standard contractual clauses, together with supplementary safeguards where appropriate.

9. Security and Incidents

We use administrative, technical, and organizational safeguards designed to protect personal data, including access controls and measures appropriate to the nature of the data. No service can guarantee absolute security. We investigate suspected incidents and notify affected controllers, individuals, or authorities when legally required.

10. Your Rights

Depending on location and context, you may have rights to access, correct, delete, restrict, or object to processing; receive a portable copy; withdraw consent; and complain to a data-protection authority. Withdrawing consent does not affect earlier lawful processing. For school-controlled student data, contact the school first; we will support verified controller requests. We may need to verify identity and may retain data where an exception applies.

11. Cookies and Choices

We use storage technologies necessary for login, language selection, security, and core functionality. Where optional analytics or marketing technologies are used, we will provide the choices required by applicable law. Browser settings may also control cookies, but blocking necessary storage can prevent parts of the Services from working.

12. Changes to This Policy

We may update this Policy to reflect changes in the Services or law. We will post the revised version with a new effective date and provide additional notice when a material change requires it.

13. Contact Us

For privacy questions, rights requests, or data-protection concerns, please use our Contact Us page. You may also complain to the supervisory authority in the country where you live, work, or believe an infringement occurred.