Last updated: September 12th, 2025

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Application refers to Goalee, the software program provided by the Company. This includes the product Commentadori, a payment interface developed by the Company for integration with third-party payment processors.
• Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.
• CCPA and/or CPRA refers to the California Consumer Privacy Act (the “CCPA”) as amended by the California Privacy Rights Act of 2020 (the “CPRA”).
• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Milva doo Beograd.
  • For the purpose of the GDPR, the Company is the Data Controller for account, billing, analytics, and security.
  • For Documents and related Employer content uploaded into the Service, the Company acts as a Data Processor on behalf of the Employer.
• Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Country refers to: Serbia.
• Data Controller, for the purposes of the GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
• Data Processor means the Company when acting on behalf of Employers in relation to processing of Documents, Document Games, and Document Q&A.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Document means any file (including PDF), URL, or plain text uploaded by a User into the Service, including subsequent enrichments.
• Document Game means a Goals game created from a Document where up to 20 questions and 4 answer options for each question (1 correct, randomized) are generated automatically. Doc Uploaders and Editors may edit these before publication and/or generate additional questions and answers about the Document.
• Document Q&A means the feature that allows Users to ask questions about a Document after completing a Document Game, with answers generated via the Cognee RAG AI memory.
• GDPR refers to EU General Data Protection Regulation.
• Personal Data is any information that relates to an identified or identifiable individual.
• Roles means the three permission levels in the Service: Standard, Doc Uploader, and Admin. Admins may also configure Alternate Domains that share the same second-level domain as the main domain.
• Service refers to the Application or the Website or both.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. This includes technology providers supporting our platform, payment processors, artificial intelligence APIs, cloud service providers, data analytics providers, and other third parties as described in this Policy. Cognee by Topoteretes, Bubble, OpenAI, Payten, PDF Generator API, and Postmark by ActiveCampaign are included as Service Providers.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to Goalee, accessible from https://goale3.com.
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
  • Under GDPR, You can be referred to as the Data Subject or as the User.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information. Personally identifiable information may include, but is not limited to:

• Name and surname
• Images
• Company data (name, address, tax identification number)
• Work email address
• Company bank account details
• Uploaded Documents (PDF, URLs, plain text, enrichments) and related metadata
• Edits made by Doc Uploaders/Editors to AI-generated question sets
• Document Q&A prompts and responses
• Usage Data

We collect images that You upload to the Service for AI-based editing and generation. These may be transmitted to third-party AI providers (OpenAI) under strict contractual terms. Documents may be transmitted to Cognee for embedding, indexing, and retrieval to power Document Games and Document Q&A.

Usage Data
Usage Data is collected automatically when using the Service and may include:

• Device IP address, browser type and version, operating system, session timestamps, unique identifiers, and diagnostics;
• Game performance data (e.g., who played, score achieved, time to completion);
• Document Q&A usage (e.g., number of questions asked per game, enforced according to subscription tier – Pro: up to 50; Premium: unlimited).

Information Collected While Using the Application
With Your prior permission, we may also collect:

• Information regarding Your location.

This information is used to provide and improve features of the Service.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

• Type: Session Cookies
• Administered by: Us
• Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

• Type: Persistent Cookies
• Administered by: Us
• Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service. Your uploaded images are processed to create AI-generated illustrations aligned with your stated interests or hobbies. We do not use these images for biometric identification purposes. Documents you upload (PDFs, URLs, text, and enrichments) are processed to generate Document Games and power Document Q&A via our sub-processor Cognee.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You, and to support Service functionality. Your uploaded images are processed by third-party AI service providers (OpenAI) under Data Processing Agreements and appropriate safeguards. Documents you upload are processed by Cognee for embedding, indexing, and retrieval as part of Document Games and Document Q&A. Cognee acts as our sub-processor under GDPR with contractual safeguards.
• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. Please note that Document Game statistics (e.g., who played, scores, completion times) are visible only to the Doc Uploader/Admin within the same Employer’s subscription, and are not shared publicly.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Documents uploaded to the Service, along with associated metadata, Document Game configurations, Doc Uploader/Editor edits, Document Q&A logs, and statistics (e.g., who played, scores, times) are retained for the duration of the Employer’s active subscription and processed solely on behalf of the Employer as Data Controller. Upon termination of the subscription, such data is deleted or anonymized, unless longer retention is required by law or necessary for dispute resolution or enforcement.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to – and maintained on – computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Our key service providers (including Bubble, OpenAI, PDF Generator API, Payten, Cognee, and Postmark) may process or store Your Personal Data outside of your country of residence, including in the United States, the EU, or other jurisdictions. Where we transfer Personal Data outside the EEA/UK/Switzerland, we ensure appropriate data protection safeguards are implemented, such as Standard Contractual Clauses (SCCs) and signed Data Processing Agreements (DPAs), as required by law.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

If You are an employee or representative of an Employer, deletion requests for Documents, Document Games, Document Q&A logs, and associated statistics will be directed to your Employer, as we process such data in our capacity as Data Processor.

Disclosure of Your Personal Data

Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

On behalf of Milva doo Beograd, we hereby oblige ourselves to safeguard the privacy of all our users. We collect only necessary, basic Personal Data about our users required for regular business operation and user notification in line with best business practice and with the aim of providing high quality services. We enable our users the possibility to choose whether they want to be included or not on marketing campaign mailing lists. All user Personal Data is strongly safeguarded and available to our employees only on a need-to-know basis. All Milva employees are required to adhere to the principle of privacy protection.

Additional safeguards are applied to Documents, Document Games, Document Q&A, and related statistics processed on behalf of Employers. These include encryption in transit, role-based access controls, and strict contractual restrictions with our sub-processor Cognee. Document Game statistics are accessible only to the relevant Employer’s authorized Users (Doc Uploaders, Admins) and are not shared externally.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Key Service Providers

• Bubble (No-Code Platform)
  • Purpose: Provides the main user interface and underlying technical infrastructure for our Application and Website.
  • Roles: Hosts user data, manages workflows, and stores data necessary for service provision.
  • Privacy Policy: https://bubble.io/privacy
  • Data Protection: Bubble includes SCCs and standard DPAs as part of its service agreements (https://bubble.io/dpa).
• OpenAI API
  • Purpose: Provides AI-powered text and image editing/generation as part of user features.
  • Roles: Processes user-entered text and images to generate outputs.
  • Privacy Policy: https://openai.com/policies/privacy-policy
  • Data Protection: OpenAI acts as a data processor under a formally signed Data Processing Agreement (DPA). Data transfers are protected by appropriate safeguards.
• PDF Generator API
  • Purpose: Generates invoices and PDF documents for our clients.
  • Roles: Receives invoice-related data for PDF creation; stores files as necessary to complete the service.
  • Privacy Policy: https://pdfgeneratorapi.com/data-security-privacy
  • Data Protection: Covered by SCCs and standard DPAs as part of standard usage (https://pdfgeneratorapi.com/data-processing-agreement).
• Payten Payment Processor
  • Purpose: Handles payment processing and related financial transactions.
  • Roles: Processes payment details securely; may have access to payment-related personal data.
  • Privacy Policy: https://www.payten.com/en/privacy-policy/
  • Data Protection: SCCs and standard DPAs in place per their service terms.
• Postmark by ActiveCampaign
  • Purpose: Handles sending automated emails through a verified API emailing server.
  • Roles: Uses user contact data (email) to deliver all details required for successfully managing a user account.
  • Privacy Policy: https://postmarkapp.com/eu-privacy
  • Data Protection: Covered by SCCs and standard DPAs as part of standard usage (https://postmarkapp.com/dpa).
• Cognee by Topoteretes 
  • Purpose: Embeds, indexes, and retrieves content from Documents to power Document Games and Document Q&A.
  • Roles: Acts as sub-processor for Documents, Document Game edits, and Document Q&A queries on behalf of Employers.
  • Data Protection: Operates under a Data Processing Agreement (DPA) with the Company and ensures compliance with GDPR, including SCCs where applicable.
  • Privacy Policy: https://www.cognee.ai 

All service providers are contractually required to process Personal Data only for the purposes specified by the Company and to implement appropriate data protection measures according to applicable laws (GDPR, CCPA/CPRA, etc.).

Artificial Intelligence and Synthetic Content Transparency

We use artificial intelligence (AI) technologies provided by OpenAI to support certain features in our Service, including text generation and image editing. In some cases, these features may generate or manipulate images of actual persons.

We also use Cognee, a EU-based Retrieval-Augmented Generation (RAG) provider, to process Documents you upload (PDF, URL, plain text, and enrichments) and to generate question sets and Document Q&A responses. Doc Uploaders and Editors can review and edit all AI-generated questions and answers before publishing Document Games.

To comply with the transparency requirements under Article 50 of the EU AI Act:

• If you use our AI-based image editing features, we will provide a clear and visible notification – either in the Service interface or alongside the relevant content – that the image has been artificially generated or manipulated using AI technology.
• If you participate in Document Games or Document Q&A, a clear notice is provided that questions, answers, and responses may have been generated by AI and are not guaranteed to be accurate.
• The purpose of these notices is to ensure all Users, and where feasible those persons depicted in manipulated or generated content, are aware of the artificial nature of such outputs.

Please note: These AI features are intended to assist and enhance your experience and do not make automated decisions about you with legal or similarly significant effects. Output generated through AI is based solely on the inputs you or your Employer provide, and is not used for profiling or automated decision-making.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

When we process Documents, Document Games, Document Q&A logs, and related statistics on behalf of Employers, we act as a Data Processor under GDPR. In such cases, the Employer is responsible for identifying the lawful basis (e.g., contract, legitimate interest, consent) for such processing, and we process such data only on Employer instructions.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it. For Documents, Document Games, and Document Q&A, requests may need to be directed to Your Employer, since we act as Processor in relation to such data.
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consent on using Your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

Where we process Personal Data as Processor (for Documents, Document Games, Document Q&A, and associated statistics), we may be required to forward your request to your Employer, who acts as Controller of such data.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

CCPA/CPRA Privacy Notice

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

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. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

• Category A: Identifiers.
  Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
  Collected: Yes.
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
  Examples: A name, signature, address, telephone number, bank account number, debit card number, or other financial information. Some personal information included in this category may overlap with other categories.
  Collected: Yes.
• Category C: Protected classification characteristics under California or federal law.
  Collected: No.
• Category D: Commercial information.
  Collected: No.
• Category E: Biometric information.
  Collected: No.
• Category F: Internet or other similar network activity.
  Examples: Interaction with our Service or advertisement; activity within Document Games or Document Q&A.
  Collected: Yes.
• Category G: Geolocation data.
  Examples: Approximate physical location.
  Collected: Yes.
• Category H: Sensory data.
  Collected: No.
• Category I: Professional or employment-related information.
  Collected: No.
• Category J: Non-public education information.
  Collected: No.
• Category K: Inferences drawn from other personal information.
  Collected: No.
• Category L: Sensitive personal information.
  Examples: Account login and password information, geolocation data, Employer-provided subscription role assignments (Standard, Doc Uploader, Admin) and Document Game statistics (e.g., who played, score, completion time).
  Collected: Yes.

Under CCPA/CPRA, personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA/CPRA’s scope, such as:
  • Health or medical information covered by HIPAA and CMIA or clinical trial data.
  • Personal information covered by sector-specific laws including FRCA, GLBA/FIPA, or the Driver’s Privacy Protection Act of 1994.

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, and Documents You upload (PDFs, URLs, or text).
• Indirectly from You. For example, from observing Your activity on our Service, such as playing Document Games or submitting Document Q&A prompts.
• Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
• From Service Providers. For example, Cognee (Document embedding and retrieval), OpenAI (AI generation), Bubble (infrastructure), Payten (payments), and other vendors that We use to provide the Service to You.

Use of Personal Information

We may use or disclose personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA/CPRA), which may include the following examples:

• To operate our Service and provide You with Our Service. This includes processing Documents to generate Document Games and to enable Document Q&A.
• To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
• To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to You when collecting Your personal information or as otherwise set forth in the CCPA/CPRA.
• For internal administrative and auditing purposes.
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
• Other one-time uses.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of Your Personal Data” section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category F: Internet or other similar network activity
• Category G: Geolocation data
• Category L: Sensitive personal information

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Share of Personal Information

We may share, and have shared in the last twelve (12) months, Your personal information identified in the above categories with the following categories of third parties:

• Service Providers (including Cognee, OpenAI, Bubble, Payten, PDF Generator API, Postmark)
• Our affiliates
• Our business partners
• Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

Sale of Personal Information

As defined in the CCPA/CPRA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as infrastructure hosting, AI processing, analytics, and support functions. These activities may be deemed a sale under CCPA/CPRA.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category F: Internet or other similar network activity
• Category G: Geolocation data
• Category L: Sensitive personal information (e.g., account login and password information, Employer-defined role assignments (Standard, Doc Uploader, Admin), and Document Game statistics such as scores and completion times)

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third-party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and We encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the “right to opt-in”) from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time.

To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

• The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
• The right to know/access. Under CCPA/CPRA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and sharing of personal information. Once We receive and confirm Your request, We will disclose to You:
  • The categories of personal information We collected about You
  • The categories of sources for the personal information We collected about You
  • Our business or commercial purposes for collecting or selling that personal information
  • The categories of third parties with whom We share that personal information
  • The specific pieces of personal information We collected about You
  • If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
    • The categories of personal information categories sold
    • The categories of personal information categories disclosed
• The right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request, please see the “Do Not Sell My Personal Information” section or contact Us.
• The right to correct Personal Data. You have the right to correct or rectify any inaccurate personal information about You that We collected. Once We receive and confirm Your request, We will use commercially reasonable efforts to correct (and direct our Service Providers to correct) Your personal information, unless an exception applies.
• The right to limit use and disclosure of sensitive Personal Data. You have the right to request to limit the use or disclosure of certain sensitive personal information We collected about You, unless an exception applies. This may include restricting access to Document Game statistics, subscription role information, or other Employer-related account data. To submit, please see the “Limit the Use or Disclosure of My Sensitive Personal Information” section or contact Us.
• The right to delete Personal Data. You have the right to request the deletion of Your Personal Data under certain circumstances, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
  • Complete the transaction for which We collected the personal information, provide a good or service that You requested (including ongoing Document Game services), or otherwise perform our contract with You.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights, including by:
  • Denying goods or services to You
  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
  • Providing a different level or quality of goods or services to You
  • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA/CPRA Data Protection Rights

Please see the “Do Not Sell My Personal Information” section and “Limit the Use or Disclosure of My Sensitive Personal Information” section for more information on how to opt out and limit the use of sensitive information collected.

Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us:

• By email: office@goale3.com
• By visiting this page on our website: https://goale3.com/privacy_policy

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

• Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
• Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if We cannot:

• Verify Your identity or authority to make the request, and
• Confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.

For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

As defined in the CCPA/CPRA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood. We do allow Service Providers to use Your personal information for the business purposes described in Our Privacy Policy, for activities such as advertising, analytics, and infrastructure support, and these may be deemed a sale under CCPA/CPRA.

Documents uploaded by Users, Document Games, Document Q&A content, and Document Game statistics are not sold. These are processed solely on behalf of Employers by Cognee and other Service Providers under strict contractual safeguards (Data Processing Agreements, SCCs).

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA/CPRA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA/CPRA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Website

If applicable, click “Privacy Preferences,” “Update Privacy Preferences” or “Do Not Sell My Personal Information” buttons listed on the Service to review your privacy preferences and opt out of cookies and other technologies that We may use. Please note that You will need to opt out from each browser that You use to access the Service.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

• “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
• “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

Limit the Use or Disclosure of My Sensitive Personal Information

If You are a California resident, You have the right to limit the use and disclosure of Your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average Consumer who requests such services or goods.

We collect, use and disclose sensitive personal information in ways that are necessary to provide the Service. This includes processing subscription role assignments (Standard, Doc Uploader, Admin) and Document Game statistics (e.g., scores, completion times) on behalf of Employers.

For more information on how We use Your personal information, please see the “Use of Your Personal Data” section or contact Us.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

Document upload features and Document Games are restricted to authorized subscription roles (Doc Uploader, Admin) and are never intended for use by children under 13.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: office@goale3.com
• By visiting this page on our website: https://goale3.com/privacy_policy