Privacy Policy


LAST UPDATED: November 22, 2022

Empathy Labs Inc. and its affiliates (collectively, “we” or “us”) want you to be familiar with how we collect, use, and disclose information.  This Privacy Policy describes our practices in connection with information that we collect through the Ambition – Learn and Earn mobile application (the “App”). 



“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.  We collect Personal Information through the App, including:  

  • Name 

  • Email address

  • Education information, such as information about your school, grade, and ID card

  • Account credentials, including username and password

  • IP address (we may also derive your approximate location from your IP address)

  • Profile picture 

Collection of Personal Information 

We and our service providers collect through the App, such as when you create an account, access or complete a course curriculum, submit a question, request, or other inquiry, or redeem rewards.

We need to collect Personal Information in order to provide the App and our related services to you.  If you disclose any Personal Information relating to other people to us or to our service providers in connection with the App, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.    


Use of Personal Information 

  • Providing the functionality of the App and fulfilling your requests.  

    • To provide the App’s functionality and related services to you, such as arranging access to your registered account and selected courses, and providing you with related benefits, course completion rewards, special promotions, and customer service.

    • To respond to your inquiries and fulfill your requests, such as when you send us questions, suggestions, compliments, or complaints, or when you request information about the App or our services.

    • To complete your transactions (such as reward redemptions), verify your information, and provide you with related benefits, special promotions, and customer service.

    • To send administrative information to you, such as changes to our terms, conditions, and policies.

  • Analyzing Personal Information for business reporting and providing personalized services. 

    • To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our App is used, so we can evaluate, improve, and report on the impact of the App and our services.

    • To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.

    • To better understand your preferences so that we can deliver content via the App that we believe will be relevant and interesting to you.

  • Allowing you to participate in sweepstakes, contests, or other promotions. 

    • We may offer you the opportunity to participate in a sweepstakes, contest, or other promotion.

    • Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information.  Please read those additional rules before choosing to participate.

  • Aggregating and/or anonymizing Personal Information.

    • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information.  We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual. 

  • Accomplishing our business purposes.

    • For data analysis, for example, to improve the efficiency of the App and our services.

    • For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements.

    • For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft. 

    • For developing new products and services. 

    • For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures.

    • For identifying and reporting usage trends, for example, understanding which parts of the App are of most interest to users.

    • For operating and expanding our business activities. 

Disclosure of Personal Information  

We disclose Personal Information: 

  • To our third-party service providers, to facilitate services they provide to us. 

    • These can include providers of services such as website hosting, data analysis, reward redemption, order fulfillment, fraud prevention, information technology and related infrastructure provision, customer service or related benefits (including special promotions), email delivery, auditing, and other services.

  • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information.  We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

  • By using the App, you may elect to disclose Personal Information, such as on profile pages and other services to which you are able to post information and content.  Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.

Other Uses and Disclosures

We may also use and disclose Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, to respond to requests from public and government authorities, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.  We may also use, disclose, or transfer your Personal Information to a third party in connection with any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our assets or stock (including in connection with any bankruptcy or similar proceedings). 



“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual.

We and our service providers may collect Other Information through the App in a variety of ways, including: 

  • Your device. 

    • We collect certain information automatically through your device, such as your operating system name and version, device manufacturer and model, and language. We use this information to ensure that the App functions properly.

  • Your use of the App. 

    • When you download and use the App, we and our service providers track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.

Uses and Disclosures of Other Information 

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy.  In some instances, we may combine Other Information with Personal Information.  If we do, we will treat the combined information as Personal Information as long as it is combined.


We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.


If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out using the unsubscribe link contained in each such marketing email.


This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the App links.  The inclusion of a link in the App does not imply endorsement of the linked site or service by us. 


In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Apple, Google, Microsoft, RIM, or any other operating system provider, wireless service provider, or device manufacturer. 


Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the App you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.  


Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or criminal background) on or through the App or otherwise to us.


The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on the App.  


If you have any questions about this Privacy Policy, please contact us at


Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.