1. Overview

SkillsPlay is dedicated to making learning awesome and we take the privacy of our users seriously. Keeping learners’ personal information safe is a priority at SkillsPlay. This Learner Privacy Policy explains how we use the personal information we collect from and about learners when they engage with BrightGame in the classroom through the products that are offered to educational organisations, employers and learners engaging with the BrightGame platform and associated SkillsPlay services. As described below, we use such personal information solely as a service provider or “data processor” to our customers.

To learn about our practices with respect to other users, including educators and trainers who sign up for  BrightGame and learner accountholders who use  BrightGame outside of the formal education environment, please read our Privacy Policy.

2. Our handling of learner information

As a trusted provider of tools that help educators and learning organisations use vocational gamification,  SkillsPlay is concerned about the use of learners’ personal information. We only request the personal information of learners that we need to provide the our services, and comply with privacy laws, such as the Family Educational Rights and Privacy Act (“FERPA”) and the Children’s Online Privacy Protection Act (“COPPA”), as applicable.

SkillsPlay does not collect, retain, use or share learners’ personal information, except as necessary for authorised educational purposes, at the direction of our learning organisation customers. Without limitation, this means that:

• We do not sell learners’ personal information.
• We do not serve targeted ads on our platforms and do not use information we collect to serve targeted ads on other services.  SkillsPlay does not use or disclose information collected through our services for any targeted advertising purposes.
• We do not build a profile of a learner other than in support of authorised learning organisation purposes.
• We do not retain learners personal information beyond the time period required to support the authorised learning organisation purposes.

We support our learning organisation customers in providing parents and eligible learners with access to their personal information and in fulfilling other requests that parents and eligible learners may make, such as to request deletion of learners’ personal information or to refuse its further collection or use.  SkillsPlay maintains a comprehensive program designed to protect the security, privacy, confidentiality and integrity of learners’ personal information.

3. Learners’ Personal information

3.1 Personal information we collect from learners

Learner players: 

SkillsPlay provides and collects only a nickname, which is anonymous and not linked to a persistent identifier, from a learner who merely plays a SkillsPlay game. We use the nickname to permit the learner to play.

If cohorts details are uploaded by educators and learning organisations, this may include names and email addresses.  These are maintained by the learning organisation within their account and used for inviting players to game event sessions, reporting or integration with broader Learning Management Systems within the learning organisation customer.

Personal information collected at a educator’s direction: Certain features of our services permit a educator to collect information about the class, as well as about individual learners, such as attendance, game participation results, and feedback provided on SkillsPlay game results (including personal game reports) and performance on  SkillsPlay games. We use such information only to provide the services to the educator, such as to permit the educator to interact with learners and track their progress over time. A learning organisation or educator may permit learners to share information with others, such as with other learners in the same class, learning organisation, or learning organisation areas.

3.2 Information collected automatically

No personal information is collected automatically from learners who engage with SkillsPlay through the our services. Product usage data that is collected by SkillsPlay from the our services is always anonymised or aggregated and cannot be linked to individual learners.

3.3 Anonymised information

We may anonymize and/or aggregate personal information so that it no longer identifies any learner. We may use and disclose such anonymized and/or aggregated information for any purpose, including for analytics purposes, to help us understand how our products are used and improve upon them.

4. Security

SkillsPlay maintains a comprehensive security program designed to protect the security, privacy, confidentiality and integrity of Personal Information within our organization. We have in place appropriate and reasonable technical and organizational measures designed to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. Our security measures include data encryption, firewalls, data use, and access limitations for our personnel and service prividers, and physical access controls to our facilities. Our service providers that process payment data, maintain the applicable Payment Card Industry (PCI) compliance levels.

Details about our security program can be found here. If you have any questions about the security of your Personal Information, you may contact us at info@brightgame.com

5. Compliance with FERPA and COPPA

We comply with FERPA and COPPA when applicable to us. When FERPA applies, we act as a ”learning organisation official” to our learning organisation or learning organisation district customer, which means that we are under the direct control of the learning organisation or district and use learners’ personal information only to provide our services to the learning organisation or district and not for our own purposes. To the extent COPPA applies, the learning organisation or district provides us with any necessary consent on behalf of learners’ parents or guardians to permit use of SkillsPlay in the classroom.

6. Changes to this Policy

We may change this Policy at any time and from time to time. The most recent version of this Policy is reflected by the version date located at the top of this. We encourage you to review this Learner Privacy Policy often to stay informed of changes that may affect you.

If we make material changes in the Policy, for example if we seek to use personal information in a materially different way than we had previously, we will provide prior notice by, for example, email or a pop-up so that you have sufficient time to evaluate the change in practice. Of course, you can always opt-out by deleting your account if you do not accept the change.

7. About SkillsPlay

Netpark Plexus

Thomas Wright Way

County Durham

TS21 3FD

England, UK

info@brightgame.com

+44-(0)1740-625-564

Safety guide for content on BrightGame

At SkillsPlay, ensuring the online safety of our users is a responsibility we take incredibly seriously.

In this content safety guide, we’ll give you insight into how we work with platform safety at BrightGame, including how we moderate content.

For details about our platform content policies and acceptable use, please see our Editorial Guidelines, Terms and Conditions and Acceptable Use Policy.

Content on BrightGame

Much of the content on the BrightGame platform is user-generated content, created and uploaded by our community of users from around the globe. In addition to this user-generated content, the SkillsPLay team and our certain approved partners also provide content on the platform.

BrightGames our users create or through choice made private or shared discretely or publicly through the BrightGame platform.

We work to maintain a safe user and player community. BrightGame is dedicated to protecting the integrity of our platform.

How do we regulate content?

Our Editorial Guidelines, Terms and Conditions, and Acceptable Use Policy regulates content and use of BrightGame. All users shall be familiar with these rules and comply with our standards for appropriate content.

Our Editorial Guidelines are designed to maintain the safety of the BrightGame platform and ensure that it does not contain content that is harmful or illegal. The Editorial Guidelines apply to all contributors to the BrightGame platform.

Our values are the basis for the content that we want on our platform. Contributors to the BrightGame platform and app shall respect our values and must not publish content that:

• Contains or encourages violence or criminal behaviour
• May threaten the safety of our users or that may encourage unsafe or harmful behaviour
• Is illegal, discriminating, clearly inappropriate, or objectionable
• Threatens the integrity and authenticity of our platform, including our users, user created and select partner content.

For more details, please see the full version of our Editorial Guidelines.

Our Terms and Conditions and the Acceptable Use Policy outline what is seen as acceptable use of the content on the BrightGame platform and app. These are binding to all users of BrightGame and dictate how our users may use and interact with the platform. This includes that users cannot publish or promote content that:

• Is illegal, threatening, defamatory, harassing, degrading, intimidating, fraudulent, deceptive, invasive, racist, or contains any type of suggestive, inappropriate, or explicit language.
• Infringes on any trademark, patent, trade secret, copyright, or other proprietary right of any party
• Contains unauthorised or unsolicited advertising.
• Impersonates any person or entity, including any SkillsPlay employees or representatives.

The content regulations also apply to the nicknames that users provide to participate in a BrightGame. Users shall not use nicknames that are inappropriate or offensive or that breach our rules for acceptable content.

User responsibility

Our users are solely responsible for the content they publish on BrightGame.  BrightGame does not endorse the correctness of the content that is provided by our users or any opinion that might be contained in such content. The use of content available to a user account on the BrightGame platform is the user’s own responsibility. We encourage users to always review BrightGames before they are played.

For more details, please visit our Terms and Conditions and Acceptable Use Policy.

How do we make sure that the content on BrightGame is safe?

BrightGame reserves the right to review, monitor, edit, or remove user content at our sole discretion. We may remove or disable access to any user content that breaches our policies, values, or standards, and we also have the right to suspend or disqualify users who don’t respect our rules.

We have implemented several safety and moderation efforts to help us keep content safe, such as:

1. Moderation

BrightGame has a growing team of trained moderators whose bespoke role is to filter out inappropriate content. We also use automated filter software to block or quarantine content that contains “triggers.” This software operates on the basis of a comprehensive set of keywords that are often used with ill intent. We continuously work to improve this list to reflect the ever-expanding nuances of language.

2. Flagging

As we will never be able to control all of our content, we rely on our community to help us keep the platform safe. We encourage users to report illegal or inappropriate content. Any adult account holder can flag individual public BrightGames for review, should they deem the BrightGame to include illegal or inappropriate content. Content flagged by our users will be reviewed and assessed by our moderator team.

This is how you flag inappropriate content:

Step 1: Contact the support team by emailing support@brightgame.com

Step 2: Provide the title of the game and explain why you find it inappropriate.

Step 3: The BrightGame will be flagged for moderation by our team.

If inappropriate it will be removed from public access, made private permanently or approved for republishing.

Once a BrightGame is whitelisted, it cannot be flagged again unless the creator makes changes to the BrightGame. If edited, the removal option is reopened.

3. Customer service response

If any user finds content that they believe is inappropriate and in breach of our terms and conditions and acceptable use policy and can reach out to our team, via our Contact Us form.

Certain approved users

On the BrightGame platform and app, you may find content from BrightGame partners.

When our users apply to become a BrightGame partner, their profile and content is evaluated by the SkillsPlay team. This includes checking alignment with our Terms and Conditions, Acceptable Use Policy, and Editorial Guidelines. When a user is certain approved as a BrightGame partner, their content will be provided with a Partner badge.  Imn addition the partner may also operate a dedicated game gallery and page.

The approval process will assist you in selecting quality content however, it is not a guarantee that inappropriate content and irregularities may not appear. Therefore, such content follows the same rules and guidelines as any other user-generated content on BrightGame.

If an approved user or partner publishes content that breaches our policies or guidelines, their user licence can be revoked and they can be excluded from BrightGame in the same way as any other user.

Questions regarding content safety

If you have any questions regarding content moderation on BrightGame, please reach out to us via the Contact us form.