FRANCHISING

Effective Date: April 17, 2019

Girl Dad Solutions LLC dba Steam Champs (“we” or “us”) respects the importance of the privacy of your
personal information. This Privacy Policy outlines our current policy on personal information concerning
center customers, website visitors, and franchisees, and covers the operations of our Steam Champs
centers, franchise operations, business development and use of our websites under steamchamps.com
and other related sites (the “Sites”), and private access portals for Steam Champs centers students and
parents (“Portals”).

 

Through the Sites and Portals, we are providing you with information about products and services
offered at independently owned and operated Steam Champs franchised locations (“Franchised
Locations”), including educational programs for children, (a) in addition to the Sites and Portals,
software platforms and as applicable, social media platforms we make available from time to time, (b)
point-of-sale systems and databases and customer management platforms (c) the ability to schedule,
modify, and/or cancel programs or services with any Franchised Locations; (d) provide information to
and complete forms with your Franchised Location; (e) enter into and use benefits under any
membership agreement entered into with your Franchised Location; (f) purchase and/or redeem gift
cards at Franchised Locations; (g) purchase services or product at any Franchised Location as a guest; (h)
view information about and find the Franchised Location nearest you; (i) request franchise information;
(j) complete customer satisfaction surveys about any Franchised Location; (k) receive email notifications,
SMS notifications, and notifications from other mediums (collectively, the “Services”).
This Privacy Policy applies to our use of Your Information as a result of you using the Sites, Portals, and
Services, and does not apply to the following:

• information collected through mediums other than the Sites, Portals, and/or Services;
• information collected through the Sites, Portals, and/or Services, where a separate privacy
policy expressly applies in lieu of (and not in addition to) this Privacy Policy, such as a
sweepstakes entry (you should refer to the official rules and privacy policy for each individual
sweepstakes for specific policies regarding information sharing and disclosure pursuant to
sweepstakes entry);
• information collected by any person or entity other than us, even if related to the Sites, Portals,
and/or Services (such as a third-party website, content, application or lead form), unless and
until such other person or entity provides such information to us; or
• non-personally identifiable information, which standing alone, cannot be used to determine
your identity; provided, however, that if we link such non-personally identifiable information
with Your Information in a manner that can be used to determine your identity, then this Privacy
Policy will apply.
Please read this Privacy Policy and our other Terms and Conditions carefully prior to accessing or using
the Sites, Portals, and/or Services. By accessing or using the Sites, Portals, and/or Services, or by clicking
to accept or agree to be bound by this Privacy Policy or our other Terms and Conditions, as applicable,
you agree to our Terms and Conditions, including the practices described in this Privacy Policy. If you do
not want Your Information used or disclosed in the manner described in this Privacy Policy, or if you do
not agree to be bound by the terms and conditions of this Privacy Policy, or our other Terms and
Conditions, then you should not use the Sites, Portals, and/or Services or provide us with Your
Information.

INFORMATION COLLECTION

We and/or Franchised Locations may collect information about you directly from you and from third
parties, as well as automatically through your use of the Sites, Portals, and/or Services.
Information collected directly from you:

When you use the Sites, Portals, and/or Services, certain areas or features may require you to provide
personal information. If you request program information on the Sites or at a Franchised Location, the
Sites or the Franchised Location collects your name, email address, phone number, etc. (“Personally
Identifiable Information” or “PII”), and information about your child or children that you provide to us
(e.g., name and birthdate). If you make a purchase through the Sites and/or Portals, we will collect your
payment information, including your PII and billing information. We also collect information from you
when you contact us such as if you request information about an independently owned and operated
Franchised Location. When you contact us, we may request your PII, geographic location, and
information about the purpose of the contact and collect this information.

If you make a reservation for a program or service through the Sites or Portals, we and the Franchised
Location at which you make a reservation will collect your PII and payment information. If you contact a
Franchised Location, that location may also collect information, including your PII, which they may
provide to us. When you contact a Franchised Location, that location may request your name and other
PII, geographic location, and information about the purpose of your contact. Other instances where you
may provide Your Information include purchasing memberships or gift cards, creating, manipulating or
updating accounts on or through the Sites or Portals, completing surveys, purchasing other products or
services, participating in forums or submitting User Generated Content, accessing our or a Franchised
Locations Wi-Fi System or other systems and platforms in connection with the Sites, Portals, and/or
Services, signing up for promotions or to receive newsletters or other materials about or otherwise for
any reason associated with our business.

We may invite you to post content on the Sites, including your comments and any other information
that you would like to be available on the Sites, which may become public. If you post content on the
Sites, all of the information that you post will be available to authorized personnel of us and Franchised
Locations. You expressly acknowledge and agree that we may access in real-time, record and store
archives of any User Generated Content on our servers to make use of them in connection with the
Sites, Portals and/or Services. If you submit a review, recommendation, endorsement, or other User
Generated Content through our Sites and Portals, or through other websites including Facebook,
Instagram, Google, Yelp, and other similar channels, we may share that review, recommendation,
endorsement or content on the Sites or other locations.

In addition, if you are a prospective franchisee, we may collect detailed information about you including
PII, and general financial information such as liquidity and assets, to evaluate your qualifications for a
Steam Champs franchise.

Information collected from third parties:

We and/or Franchised Locations also may collect Your Information from third parties. For example, if we
make gift cards available for purchase through the Sites or Portals, we may collect the recipient’s and
the purchaser’s PII and the purchaser’s payment information.

From time to time, you may interact with third-party sources in connection with the Sites, Portals,
and/or Services, and we may therefore collect information about you from these sources. Third-party
sources may include social media websites (i.e., Facebook, LinkedIn, Twitter, Instagram, Snapchat or
others), blogs, other users, our third-party service providers and our other business partners. For
example, if you use, access or interact with the Sites or Portals on or through a social media website or
any features of such social media website (such as a Facebook Like button), then we will receive certain
information about you from the social network automatically. The information that we will receive
depends on the social network and your privacy settings.

Any information about you that we collect from such third-party sources will be subject to the terms and
conditions of this Privacy Policy and may also be subject to the privacy policies and practices of such
sources. You should review all terms of use and privacy policies of such sources prior to disclosing
information to them. If you have any questions about how these sources use your information or their
respective terms of use or privacy policies, you should contact them directly.

We and/or a Franchised Location may also supplement or verify information about you from a service
provider.

Information collected automatically:

We may automatically collect the following information about your use of the Sites, Portals, and/or
Services through cookies, web beacons, and other technologies: your domain name; your browser type
and operating system; web pages you view; links you click; your IP address; the length of time you visit
the Sites, Portals, and/or Services; and the referring URL or the webpage that led you to the Sites. In
addition, we may collect information regarding application-level events, such as crashes, and associate
that temporarily with your account to provide customer service.

We and/or Franchised Locations may combine this information with other PII collected from you (and
third-party service providers may do so on behalf of us or Franchised Locations). Most web browsers
automatically accept cookies, but if you prefer, you can edit your browser options to block them in the
future. Visitors to the Sites who disable cookies will be able to browse certain areas of the Sites, but
some features may not function.
Location data:
We and/or Franchised Locations may use and store information about your location if you give us
permission to do so (“Location Data”). We use this data to provide certain features of our Sites and to
improve and customize our Sites. You can enable or disable location services when you use our Sites at
any time by way of your device settings.

Tracking & cookies data:

We use cookies and similar tracking technologies to track the activity on our Sites and/or Portals, and
we hold certain information. Cookies are files with a small amount of data which may include an
anonymous unique identifier. Cookies are sent to your browser from a website and stored on your
device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track
information and to improve and analyze our Sites and/or Portals. 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 portions of our Sites or Portals.

HOW YOUR INFORMATION IS USED

We and/or Franchised Locations may use Your Information, including your PII, for the following
purposes:

• To provide the Services to you, to communicate with you about your use of the Services, to
respond to your inquiries, to fulfill your orders, and for other customer service purposes.
• To tailor the content and information that we and/or Franchised Locations may send or display
to you, to offer location customization and personalized help and instructions, and to otherwise
personalize your experiences while using the Sites, Portals, and/or the Services.
• For marketing and promotional purposes. For example, we and/or Franchised Locations may use
your information, such as your email address and/or cellular phone number, to send you news
and newsletters, special offers, and promotions, or to otherwise contact you about products or
information that may interest you. We and/or Franchised Locations also may use the
information that is collected from you to assist in advertising the Services on third-party
websites. You may opt out of receiving any, or all, of these communications from us by following
the unsubscribe link or the instructions provided in any email we send.
• To better understand how users access and use the Sites, Portals, and/or Services, both on an
aggregated and individualized basis, in order to improve the Sites, Portals, and/or Services and
respond to user desires and preferences and for other research and analytical purposes.
• To protect the rights and interests of us and/or Franchised Locations, such as to resolve any
disputes, enforce the Terms and Conditions, or to respond to legal process (such as a summons
in a lawsuit or subpoena).
• To allow you to participate in interactive features on our Sites and/or Portals, and in any other
manner we describe when you provide Your Information.

LEGAL BASIS FOR PROCESSING YOUR INFORMATION UNDER THE GENERAL DATA PROTECTION
REGULATION (GDPR)

If you are from the European Economic Area (EEA), our legal basis for collecting and using the personal
information described in this Privacy Policy depends on the Personal Data we collect and the specific
context in which we collect it.

We may process Your Information because:

• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it is not overridden by your rights
• For payment processing purposes
• To comply with the law

RETENTION OF DATA

Steam Champs will retain your Your Information only for as long as is necessary for the purposes set out
in this Privacy Policy. We will retain and use your Your Information 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.

Steam 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 Sites and/or Portals, or we are legally obligated to retain this data for longer periods.

TRANSFER OF DATA

Your 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
from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we
transfer the data, including Your Information, to United States and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your
agreement to that transfer.

We will take all the steps reasonably necessary to ensure that your data is treated securely and in
accordance with this Privacy Policy and no transfer of your Your Information 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.

SHARING INFORMATION

Neither we nor Franchised Locations will share your credit card number or any other financial
information with any third party except to complete your transaction and to verify your credit card
information. We and/or Franchised Locations may share your personal information with third parties in
the following instances:

Legal Disclaimer:

We and/or Franchised Locations shall disclose Your Information when required by law or under the
good-faith belief that such action is necessary under applicable law. We and/or Franchised Locations
may disclose Your Information in order to establish or exercise its or their legal rights or defend against
legal claims. We and/or Franchised Locations also may share information in order to investigate,
prevent, or take action regarding illegal activities, suspected fraud, to protect our and/or Franchised
Locations’ property or interests or that of their agents and employees, and to protect guests of a
Franchised Location, personal safety, and/or the public.

In addition, since our database is a business asset, in the event we are reorganized or sold to or merged
with another company, we may sell, assign, or transfer Your Information to a purchaser of all or
substantially all of our business assets, or to an affiliate, as applicable. We also may provide your
information to our affiliates and related entities without restriction.

Business Transaction

If we are involved in a merger, acquisition or asset sale, Your Information may be transferred. We will
provide notice before Your Information is transferred and becomes subject to a different Privacy Policy.

Aggregate Information (non-personally identifiable):

We and/or Franchised Locations may share some aggregated demographic information (age, zip codes)
with some of their partners. This is not linked to any PII. We and/or Franchised Locations may use thirdparty advertising companies to serve ads on its/their behalf. These companies may employ cookies andaction tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness.

Third-Party Service Providers:

We and/or Franchised Locations may disclose information about individual users to third parties
(“Service Providers”) who provide services to us and Franchised Locations or have a contractual
relationship with us or a Franchised Location. These third parties provide a variety of services to us
and/or Franchised Locations, including, without limitation, processing and verifying credit card
information, tracking internet marketing campaigns, and processing credit card transactions. In addition,
these third-party services may include enhancing the information we and/or Franchised Locations
collect about customers of the Franchised Locations. We and/or Franchised Locations may also use
third-party email providers to assist with sending marketing emails for us or on behalf of Franchised
Locations.

Third-Party Analytics:

We use automated devices and applications, such as Google Analytics, to evaluate usage of the Sites
and, to the extent permitted, the Portals. We and/or Franchised Locations also may use other analytic
means to evaluate the Services. We use these tools to help it improve the Services, performance, and
user experiences. These third-party entities may use cookies and other tracking technologies to perform
their services. We and Franchised Locations do not share your PII with these third parties, however.

Do-Not-Track:

Currently, the Sites and Portals do not recognize browser “do-not-track” requests. You may, however,
disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of
targeted advertising by following the instructions in the Third-Party Ad Networks section below.

Third-Party Ad Networks:

We may use third parties, such as network advertisers, to serve advertisements on third-party websites
or other media (e.g., social networking platforms). This enables us and these third parties to target
advertisements to you for products offered by us and products and services offered by Franchised
Locations in which you might be interested. Third-party ad network providers, advertisers, sponsors,
and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs),
Flash LSOs, and other tracking technologies to measure the effectiveness of their ads and to personalize
advertising content to you. These third-party cookies and other technologies are governed by each third
party’s specific privacy policy, not this one. Certain third-party advertising networks that deliver
behavioral advertising are members of the Network Advertising Initiative (“NAI”). You can prevent NAI
member companies from collecting preference data about you by going to this
site http://optout.aboutads.info/?c=2#!/ and following the NAI’s directions. Note that if you opt-out
through the NAI, you will still receive advertising. In addition, if you opt-out through the NAI and later
delete your cookies, use a different browser or buy a new computer, you will need to renew your optout choice.

Third-Party Remarketing

We use remarketing services to advertise on third party websites to you after you visited our Sites. We
and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to
our site.

Third Party Payments

We may provide paid products and/or services within the Sites and/or Portals. In that case, we use thirdparty services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our thirdparty payment processors whose use of your personal information is governed by their Privacy Policy.

These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security
Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and
Discover. PCI-DSS requirements help ensure the secure handling of payment information.

COMMUNICATIONS FROM THE SITES AND/OR APPLICATION(S) AND YOUR CHOICES

Transactions and Service Announcements:

Users who utilize the Sites and/or Portals to make a purchase or reservation will receive a number of
emails throughout the transaction process and they may sometimes receive phone calls from our
Customer Service Department and/or Franchised Locations to ensure smooth transactions. Users who
are customers of a Franchised Location will also receive emails and notifications from us regarding their
children(s) activities or progress at the Franchised Location. We and Franchised Locations may also
occasionally send out service-related announcements, for instance, if service on the Sites is temporarily
suspended for maintenance. Generally, these communications are not promotional in nature, and users
will receive them as long as their accounts are open.

Special Offers, Newsletters, and Updates:

Out of respect for the privacy of users, we and Franchised Locations present the option to not receive
these types of communications, as explained in the Choice and opt-out section below.
Choice and opt-out:

A user can change their opt-in or opt-out status in several ways:

• Communications. If you do not wish to receive notifications, text messages, alerts, posts,
notices, emails or other communications from us, you can opt-out of receiving such
communications from us (other than service-related communications, such as those
communications related to the completion of your registration, correction of user data, change
of password and other similar communications essential to your transactions on or through the
Sites, Portals and/or Services through your account settings or, to the extent applicable, by using
the unsubscribe process at the bottom of such communication or by e-mailing us
at privacy@codeninjas.com. We will remove you from our marketing lists within a reasonable
period of time and as required by applicable law. If you opt-out from receiving our marketing
communications, you may continue to receive service-related communications, such as
communications that are essential to your transactions on or through the Sites, Portals and/or
Services).
• Accessing and Correcting Account Information. If any Sites or Application allows you to create an
account with us, then you may be able to review or update some or all of Your Information (as
applicable) by logging into that Sites or Application, visiting your account profile page and
making changes.

SECURITY

We and Franchised Locations take reasonable precautions to protect users’ information. When users
submit information via the Sites and/or Portals, we and Franchised Locations take steps to protect users’
information both online and off-line.
Although we and Franchised Locations endeavor to create secure and reliable Sites and Portals and to
safeguard against unauthorized disclosures of information, neither we nor Franchised Locations can
assure you that Your Information that we and/or Franchised Locations collect will never be disclosed in a
manner that is inconsistent with this Privacy Policy. You hereby acknowledge and agree that the Steam
Champs Entities (as defined in the Terms and Conditions) are not responsible for any intercepted
information sent via the internet or through the Portals, and you hereby release the Steam Champs
Entities from any and all claims arising out of or related to the use of any intercepted information in a
manner that may violate this Privacy Policy, the law, and/or your personal privacy.

EXTERNAL LINKS

The Sites and/or Portals may contain links to other websites maintained by third parties. Please be
aware that we exercise no control over linked sites and the Code Ninjas Entities (as defined in the Terms
and Conditions) are not responsible for the privacy practices or the content of such sites. Each linked
site maintains its own independent privacy and data collection policies and procedures, and you are
encouraged to view the privacy policies of these other sites before providing any personal information.
You hereby acknowledge and agree that the Steam Champs Entities (as defined in the Terms and
Conditions) are not responsible for the privacy practices, data collection policies and procedures, or the
content of such third-party sites, and you hereby release the Steam Champs Entities (as defined in the
Terms and Conditions) from any and all claims arising out of or related to the privacy practices, data
collection policies and procedures, and/or the content of such third-party sites.

MARKETING USING SMS AND EMAILS

Where lawful to do so, and subject to your consent where required, we may communicate with you by
SMS and email to tell you about our products and services. If you wish to opt-out of receiving marketing
communications, contact please us directly and we will stop sending you communications.

YOUR DATA PROTECTION RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We
aim to take reasonable steps to allow you to correct, amend, delete or limit the use of Your Information.
If you wish to be informed about what information we hold about you and if you want it to be removed
from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• 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 Information directly within your account
settings section. If you are unable to perform these actions yourself, please contact us to assist
you.
• The right of rectification. You have the right to have your information rectified if that
information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of Your Information.
• The right of restriction. You have the right to request that we restrict the processing of your
personal information.
• The right to data portability. You have the right to be provided with a copy of the information
we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time
where we relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your
Personal Data. For more information, please contact your local data protection authority in the
European Economic Area (EEA).

SPECIAL INFORMATION FOR CALIFORNIA CONSUMERS

Your Rights Under the California Consumer Privacy Act:

If you are a California resident, California law may provide you with certain rights with regard to your PII
under the California Consumer Privacy Act (“CCPA”). Throughout this Privacy Policy you will find
information required by CCPA regarding the categories of PII collected from you, the purposes for which
we use PII, and the categories of third parties your information may be shared with. This information is
current as of the date of the Policy and is applicable in the 12 months preceding the effective date of the
Policy.

As a California resident, the CCPA provides you the ability to make inquiries regarding to your PII.
Specifically, the degree to which you have inquiries beyond what is already provided in this Privacy
Policy, you have the right to request disclosure about the collection and use of your PII over the past 12
months, including:

• the categories of PII collected about you;
• the categories of sources for the PII collected about you;
• the business or commercial purpose for collecting your PII;
• the categories of third parties with whom your PII was shared;
• the specific pieces of PII collected about you;
• if your PII was disclosed for a business purpose, the PII categories disclosed and the categories
of third parties to which the information was disclosed;
• if your PII was sold in the past 12 months, the PII categories sold and the categories of third
parties to which the information was sold (NOTE: CODE NINJAS DOES NOT SELL YOUR PII).
Please note that you may only make the above requests twice in a 12-month period. You also have the
right to request that any of your PII collected and retained be deleted, subject to certain exceptions.
Finally, you have the right to not receive discriminatory treatment by Code Ninjas or any business for
exercising any of the rights provided under CCPA.

You may submit a request regarding your rights under CCPA by emailing us at info@steamchamps.com
or calling (347) 391-3438.

If we receive a CCPA request from you, we will first make a determination regarding the applicability of
the law, and we will then take steps to verify your identity prior to responding. The steps to verify your
identity may vary based on our relationship with you, but, at a minimum, it will take the form of
confirming and matching the information submitted in the request with information already held by
Steam Champs and/or contacting you through previously used channels to confirm that you submitted
the request (i.e. confirming identity through the email that we have on file, not the email submitted to
make the request).

Your rights as stated here can also be exercised by an authorized agent on your behalf. Steam Champs
will follow the standards set by the Attorney General of California regarding designation of an
authorized agent to exercise rights under CCPA. You may review information available through the
Attorney General website (https://www.oag.ca.gov/privacy/ccpa) regarding how an individual can be
designated as an authorized agent under CCPA.

Direct Marketing:

In addition to CCPA, California residents may have certain rights with regard to marketing under
California Civil Code § 1798.83. Individuals who are residents of California and have provided their PII to
us may request information regarding our disclosures, if any, of their personally identifiable information
to third parties for direct marketing purposes. Such requests must be submitted to us
at: privacy@codeninjas.com.

California privacy rights requests must include the reference “Request for California Privacy
Information” on the subject line and in the body of the message and must include the e-mail address or
mailing address, as applicable, for us to send our response. This request may be made no more than
once per calendar year. We reserve the right not to respond to requests submitted other than to the
address specified above.

Do Not Track:

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser
to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by
visiting the Preferences or Settings page of your web browser.

CHILDREN UNDER 13

We support the Children’s Online Privacy Protection Act (“COPPA”), and our goal is to minimize the
information gathered from and disseminated about kids under 13 while permitting them active
participation with the trustworthy information and educational services that we and our Franchised
Locations provide.

We have strict limitations about what personal information can be collected and viewed about kids
under 13 and how and when they can be contacted. Please see our Children’s Privacy Policy for
additional information pertaining to our policies relating to the use of the services by children under the
age of 13.

CONTACT US

Users with questions or concerns regarding their privacy or this Privacy Policy should
contact privacy@codeninjas.com.

CHANGES IN THIS PRIVACY POLICY

If we decided to change this Privacy Policy, we will post those changes to this page on the Sites and
other places we deem appropriate so that you are aware of what information we and/or independently
owned and Franchised Locations collect, how it is used, and under what circumstances, if any, it is
disclosed or shared.

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we make
material changes to this Policy, we will notify you here, by email at the most recent email address, if any,
you provided to us, or by means of a notice on the Sites and/or Portals.