Privacy Policy

Privacy Policy

Introduction

Welcome to GoPlay AI Ltd. ("GoPlay", “we”, “us”, or “our”), a beta-phase platform designed to connect families with engaging activities for children. As we continue to develop and improve our services, we value your feedback on all aspects of our platform, including this Privacy Policy. This Privacy Policy applies to all personal information collected by GoPlay through its web platform, including any information provided by parents, children, and activity providers. The purpose of this policy is to demonstrate GoPlay's firm commitment to the protection of privacy and the importance of maintaining transparency in our practices. We strive to communicate our privacy practices in a clear and understandable manner.

This policy is applicable to all users (“you”) of GoPlay's platforms and services, and governs the collection, use, disclosure, and protection of personal information. It is designed to ensure compliance with applicable privacy laws and regulations in Ontario, Canada.

The Privacy Policy is subject to change, and any updates will be reflected on this page. The last update to this policy was made on July 18, 2025. Users are encouraged to review the policy periodically to stay informed of any changes.

Accountability & Contact

In compliance with privacy laws, GoPlay acknowledges its accountability for the personal information it collects, uses, discloses, and otherwise manages. GoPlay ensures that all such activities are conducted in a manner that respects the privacy of individuals. To this end, GoPlay has appointed a Privacy Officer responsible for overseeing GoPlay's compliance with applicable privacy laws and this Privacy Policy.

For any inquiries, concerns, or complaints regarding privacy matters, individuals may contact GoPlay's Privacy Officer at the following address:

Email: dan@goplay.ai

GoPlay also acknowledges its responsibility for personal information that is processed on its behalf by third-party service providers and activity providers. All providers must sign data protection agreements that include strict confidentiality obligations, data handling requirements, and security measures. GoPlay commits to using contractual or other means to provide a comparable level of protection while the information is being processed by such parties, and regularly audits provider compliance with these requirements.

What Personal Information We Collect

This Privacy Policy outlines the categories of personal information that GoPlay collects and how this information is collected, which are detailed below for transparency and understanding.

• Information from Parents: We collect only essential information required for service delivery from parents or legal guardians: name, primary contact information, basic account credentials, and payment data (only when required for paid services). We do not collect additional personal information unless strictly necessary for specific service features.
• Information about Children: Through parents or legal guardians only, we collect the minimum necessary information about children: first name and age. Additional preferences are provided by parents only when strictly necessary for specific activities. We are committed to safeguarding children's privacy and explicitly prohibit collecting any information directly from children or any sensitive personal data about children.
• Information from Providers: We collect names, contact information, credentials, business information, and service details from our activity providers to facilitate and verify the provision of services. This may include background checks and qualification verification where required by law.
• Automatically Collected Information: Through the use of cookies, and other tracking technologies, we automatically collect data related to your browser or device, as well as IP addresses. Our beta phase employs minimal data collection practices to respect user privacy.

Information is collected either through direct input from users or automatically through the use of our services. Our Privacy Officer oversees our data collection practices to ensure they adhere to applicable laws and this Privacy Policy.

Why We Collect Personal Information

We collect personal information from individuals for the following purposes:

• To facilitate account creation and registration for activities, ensuring age appropriate access and filtering.
• To communicate service notifications, updates, and other relevant information related to the services offered.
• To engage in marketing and promotional activities; however, such communications will only be sent to individuals who have explicitly opted in to receive them.
• To enhance and personalize the user experience on our platforms.

It is GoPlay's policy to collect and use only the minimum amount of personal information necessary to achieve specific, identified purposes. We use personal information only for the purposes for which it was collected and for closely related purposes that would be within the reasonable expectations of the individual, unless the individual has given explicit consent for a broader use. We regularly review our data collection practices to ensure we are not collecting unnecessary information. GoPlay does not sell personal information or use it for purposes unrelated to the services provided.

When and Why We Share Your Information

We may disclose your personal information to third parties in certain circumstances. For example, when a parent or guardian books an activity on behalf of their child, we will share limited information with the activity provider in order to facilitate the booking. This information includes the child's first name, age, and any relevant preferences or requirements. We will also share the parent's contact information for activity-related communications. Rest assured, our activity providers are contractually obligated to only use this information for the purpose of completing the booked activity and are not allowed to use it for any other reason.

In order to operate and improve our platform, we may also disclose personal information to our trusted third-party service providers. These providers help us with a variety of tasks, including storing and processing data, sending communications, analyzing platform usage, processing transactions, and providing customer support. We carefully select these service providers and require them to adhere to strict confidentiality and security measures. They are also only allowed to process data according to our instructions and must delete or return it when our relationship ends.

There may also be instances where we are legally required or compelled to disclose personal information, such as in response to a court order or lawful request by a public authority. Additionally, in the event of a business transfer, merger, or sale of assets, we may disclose personal information as part of this process. However, we will always take the necessary precautions to ensure the security and confidentiality of your personal information.

At no point do we share personal information with third parties for marketing purposes without obtaining explicit consent from the user. If you have any questions or concerns about these disclosures, please do not hesitate to contact our Privacy Officer. We are committed to being transparent and open about our data practices and will always work to protect your privacy.

Do We Transfer Your Data Outside of Canada?

GoPlay recognizes that in the course of its operations, personal information collected from individuals within Ontario, Canada, may be stored, accessed, or processed outside of Canada, including but not limited to, in the United States through cloud services. In such cases, GoPlay AI commits to ensuring that the personal information is protected with a level of security that is comparable to the protection it would receive under Canadian law.

The Privacy Officer will oversee the transfer of personal information to foreign jurisdictions, ensuring that all such transfers comply with applicable privacy laws and regulations. Prior to transferring personal information outside of Canada, we will take all reasonable steps to ensure that the receiving party has in place a privacy policy and security measures that meet or exceed the protections offered by Canadian privacy laws. This may include entering into agreements that require the receiving party to provide a standard of protection equivalent to that required by the privacy laws of Canada.

In the event of a data breach that may affect the privacy of our users, we will promptly notify affected individuals and relevant authorities as required by law. Our notification will include details about the nature of the breach, the information affected, steps we are taking to investigate and mitigate the incident, and recommendations for affected users to protect themselves. We maintain an incident response plan to ensure swift and effective handling of any potential data breaches.

Individuals concerned about the transfer of their personal information outside of Canada are encouraged to contact the Privacy Officer for further information on the measures GoPlay takes to protect personal information when it is transferred or stored outside of Canada.

How Long We Keep Your Information

GoPlay has established clear data retention policies to ensure we keep personal information only as long as necessary to fulfill the purposes for which it was collected or as required by law. Our data retention practices are designed to ensure that we comply with legal obligations and safeguard your information.

We regularly review our data retention periods and update them as necessary to ensure compliance with applicable laws and to fulfill our operational requirements. Any personal information that is no longer needed for its intended purpose or to comply with legal requirements will be either securely deleted or anonymized.

Our retention practices include:

Account Inactivity: If your account is inactive for more than 12 months, we will contact you to confirm if you wish to maintain it. If we do not receive a response within 3 additional months, we may delete or anonymize your account data.

Activity Records: Information related to activities and bookings is retained while your account remains active and is deleted when your account is terminated.

Financial Records: Where applicable, we retain financial transaction records for up to 7 years to comply with audit requirements and tax laws.

Service Improvement Data: During our beta phase, we may retain certain anonymized usage data to help improve our services, but this data cannot be linked back to individual users.

If you have questions about our data retention policies or how we manage your personal information, please contact our Privacy Officer

Consent

GoPlay is committed to protecting the privacy of individuals and ensuring that personal information is collected, used, and disclosed in a manner consistent with this Privacy Policy and applicable laws. To this end, GoPlay requires the consent of individuals prior to or at the time of collecting, using, or disclosing their personal information.

GoPlay's platform is designed to be strictly parent-mediated for children under fifteen (15). Only parents or legal guardians can create accounts and submit information about their children. Children cannot create accounts or provide information directly. During account creation, we implement verification measures to confirm parental authority and provide clear explanations about what information we collect and why. For example, when adding a child to your account, we'll explain that we collect your child's first name and age to match them with age-appropriate activities and to let providers know who will attend. When booking specific activities, we may request additional information like activity preferences or special requirements to ensure your child's needs are met. When parents submit their child's information, they provide express consent for GoPlay to collect, use, and disclose this information as needed to deliver our services. Additional express consent will be sought for any marketing communications or the collection of optional data fields not required for basic platform functionality.

Questions or concerns regarding GoPlay's consent practices can be directed to the Privacy Officer.

Children's Privacy

GoPlay AI recognizes the importance of protecting children's privacy and has designed its platform to ensure all children's data is submitted and managed exclusively by parents or legal guardians. Our platform architecture prevents children under thirteen (13) from creating accounts or submitting information directly, requiring that all information about children be provided through verified parent-controlled accounts. During account creation, parents must provide express consent for the collection, use, and disclosure of their child's information. If we discover that a child has somehow submitted information directly or without parental consent, we will immediately delete such information from our records and investigate how our safeguards were circumvented to prevent future occurrences.

Parents or legal guardians who believe that their child has provided us with personal information without their consent can contact our Privacy Officer at any time to request that this information be reviewed, updated, or removed from our records.

What Are Your Rights?

GoPlay recognizes the rights of individuals with respect to their personal information. Users, including parents or legal guardians acting on behalf of their children, have the right to:

• Access their personal information held by GoPlay.
• Request correction of their personal information if it is inaccurate, incomplete, or out-of-date.
• Delete their personal information, subject to applicable legal and regulatory retention requirements.
• Withdraw express consent for the use of their personal information at any time, with the understanding that such withdrawal may affect the availability or quality of services provided by GoPlay.

Requests related to the above rights can be directed to the Privacy Officer. It is important to note that while GoPlay endeavours to accommodate all requests, there may be circumstances where legal and regulatory obligations require the retention of personal information for a specified period. In such cases, the individual will be informed of the reasons for retaining their personal information.

If you have questions about our data retention policies or how we manage your personal information, please contact our Privacy Officer.

How Do We Protect Your Information?

GoPlay has implemented a series of technical and organizational measures designed to safeguard personal information against loss, theft, unauthorized access, disclosure, copying, use, or modification. Among these measures, GoPlay employs industry- standard encryption technologies, such as Secure Socket Layer (SSL) encryption, to protect personal information during transit. Additionally, access to personal information is strictly controlled and limited to employees and contractors who require such access to perform their job functions.

In recognition of the heightened need to protect children's personal information, GoPlay takes extra precautions to ensure that reasonable protections are in place, in accordance with the best practices and legal requirements for the protection of children's privacy. When you add a child to your account or book an activity, we will clearly explain what information we are collecting and why. For example, we collect your child's first name and age to match them with age-appropriate activities and to enable activity providers to properly identify participants. We limit the collection of children's personal information to only what is necessary for these specific purposes.

In the event of a data breach that could pose a risk to your personal information, we will promptly notify you via email and/or prominent notice on our website, providing details about what occurred and what steps we are taking in response. We are committed to complying with the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable privacy legislation, which includes notifying both affected individuals and relevant authorities when a breach poses a real risk of significant harm. We will provide guidance on steps you can take to protect yourself and keep you informed of our investigation and remediation efforts.

Questions or concerns regarding GoPlay AI Ltd.'s security practices may be directed to the Privacy Officer.

User Controls & Choices

We are committed to ensuring that you have control over your personal information. In accordance with privacy laws, we provide the following controls and choices to our users:

• Marketing Communications: We require express consent from you before sending any marketing communications. You have the right to withdraw your consent at any time by using the opt-out links provided in our communications.
• Cookies and Analytics: If we use cookies or similar technologies for analytics and personalized content, we will offer clear guidance on how you can opt-out of such tracking.
• Data Access and Correction: You have the right to access, update, or correct your personal information held by us. Please contact our Privacy Officer for assistance.
• Data Retention: Your personal information will be retained in accordance with our Data Retention policy, only for as long as necessary to fulfill the purposes for which it was collected and to comply with our legal obligations.
• Data Security: We employ SSL technology and other security measures to protect your personal information from unauthorized access, disclosure, alteration, loss, or destruction.
• Data Breach Response: In the event of a Data Breach, we will take immediate steps to mitigate the breach and will notify affected individuals in accordance with applicable laws.

Policy Updates

GoPlay reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. However, we will make every effort to ensure that any material changes to this policy will be notified to you by posting an updated version on our website and/or by sending you an email notification, if you have provided us with your email address. The date of the last revision of this Privacy Policy will be indicated at the bottom of this page.

It is your responsibility to regularly review this Privacy Policy to be informed of how GoPlay is protecting your information. Your continued use of the service after any changes or revisions to this Privacy Policy indicates your agreement with the terms of such revised Privacy Policy.

International Considerations

GoPlay is currently focused on users in Canada. If we expand to the U.S. or Europe, we will update this policy to reflect additional requirements under COPPA and GDPR, including children's rights, lawful processing bases, and international data transfers.

How to Contact GoPlay

If you have any questions about this Privacy Policy, or if you wish to make a complaint about how GoPlay has handled your personal information, you may contact our Privacy Officer at the following email address: dan@goplay.ai.

We take all complaints seriously and will respond to your inquiry within a reasonable timeframe. If you are not satisfied with our response, you have the right to escalate your complaint to the Office of the Privacy Commissioner of Canada. For more information on how to file a complaint, please visit the Commissioner's website at www.priv.gc.ca.