Privacy Policy

1. Introduction

Learngistics ("Company," "we," "us") operates the Enga.gd WON platform ("Service"). This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our Service. We are committed to protecting your privacy in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), the European Union's General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA), as applicable.

2. Information We Collect

2.1 Information You Provide

• Account information: Name, email address, and profile picture provided through our OAuth authentication provider
• Organization data: Organization names, team member information, and branding assets you upload
• Participant data: Names, email addresses, point values, and other data you upload for use with the wheel spinner
• Event data: Event names, descriptions, and associated wheel configurations
• Payment information: Billing details processed through our third-party payment provider (we do not store full payment card numbers)

2.2 Information Collected Automatically

• Usage data: Pages visited, features used, timestamps, and interaction patterns
• Device information: Browser type, operating system, screen resolution, and device identifiers
• Log data: IP addresses, access times, and referring URLs
• Cookies and similar technologies: Session cookies for authentication and analytics cookies for service improvement

3. How We Use Your Information

We use your personal information for the following purposes:

• Providing the Service: Operating the wheel spinner, managing your account, and processing your events
• Authentication: Verifying your identity and maintaining secure sessions
• Communication: Sending service-related notifications, including team invitations and account updates
• Improvement: Analyzing usage patterns to improve the Service's features, performance, and user experience
• Support: Responding to your inquiries and providing technical assistance
• Legal compliance: Meeting our obligations under applicable laws and regulations

4. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA) and the United Kingdom, we process personal data based on the following legal grounds:

• Contract performance: Processing necessary to provide the Service you requested
• Legitimate interests: Improving the Service, preventing fraud, and ensuring security
• Consent: Where you have given explicit consent for specific processing activities
• Legal obligation: Processing required to comply with applicable laws

5. Data Sharing and Disclosure

We do not sell your personal information. We may share your data in the following limited circumstances:

• Service providers: Third-party vendors who assist us in operating the Service (hosting, analytics, payment processing), bound by data protection agreements
• Team members: Within your organization, other members may see shared event data and participant lists as part of normal Service functionality
• Legal requirements: When required by law, court order, or governmental authority
• Business transfers: In connection with a merger, acquisition, or sale of assets, with appropriate notice to affected users

6. Data Storage and Security

Your data is stored on secure servers with industry-standard encryption in transit (TLS) and at rest. We implement appropriate technical and organizational measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal information. While we strive to protect your data, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

7. Data Retention

We retain your personal information for as long as your account is active or as needed to provide the Service. When you delete your account, we will delete or anonymize your personal data within 30 days, except where retention is required by law or for legitimate business purposes (such as resolving disputes or enforcing our Terms). Participant data uploaded for events is retained until you delete it or your account is terminated.

8. Cookies and Tracking Technologies

We use cookies and similar technologies to:

You can control cookies through your browser settings. Disabling essential cookies may prevent you from using certain features of the Service.

9. Your Rights

9.1 Under PIPEDA (Canada)

As a Canadian resident, you have the right to:

• Access your personal information held by us
• Request correction of inaccurate personal information
• Withdraw consent for the collection, use, or disclosure of your personal information (subject to legal or contractual restrictions)
• File a complaint with the Office of the Privacy Commissioner of Canada

9.2 Under GDPR (EEA/UK)

If you are in the EEA or UK, you have the right to:

• Access, rectify, or erase your personal data
• Restrict or object to processing
• Data portability (receive your data in a structured, machine-readable format)
• Withdraw consent at any time
• Lodge a complaint with your local data protection authority

9.3 Under CCPA (California)

If you are a California resident, you have the right to:

• Know what personal information we collect, use, and disclose
• Request deletion of your personal information
• Opt out of the sale of personal information (we do not sell personal information)
• Non-discrimination for exercising your privacy rights

10. International Data Transfers

Your data may be transferred to and processed in countries other than your country of residence, including Canada and the United States, where our servers and service providers are located. When we transfer data internationally, we ensure appropriate safeguards are in place, including standard contractual clauses approved by relevant authorities, to protect your personal information in accordance with applicable data protection laws.

11. Children's Privacy

The Service is not directed to children under the age of 16. We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal information from a child under 16, we will take steps to delete that information promptly. If you believe a child has provided us with personal information, please contact us at [email protected].

12. Third-Party Links and Services

The Service may contain links to third-party websites or services, including the Enga.gd platform. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you access through our Service.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. Material changes will be communicated through the Service or via email. The "Effective" date at the top of this page indicates when the policy was last revised. Your continued use of the Service after changes take effect constitutes acceptance of the updated policy.

14. Contact Us

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about how we handle your data, please contact us:

For complaints regarding our handling of your personal information, you may also contact the Office of the Privacy Commissioner of Canada.