Privacy Statement

PRIVACY STATEMENT

OVERVIEW
Honest Game’s mission is to build a roadmap for all high school student athletes to achieve academic eligibility for college sports.  We collect data from students to fulfill this mission and to enhance the likelihood that students will complete their academic and athletic journeys as collegiate student-athletes.

By using our Site and Services you accept that your personal information will be handled as set forth below in this Policy.

Honest Game Corporation

PRIVACY POLICY

Effective Date: November 24, 2021

In this Privacy Policy, any use of the words “you”, “yours,” or similar expressions refers to users of the Site and Services. References to “we”, “us, “our” or similar expressions refer to Honest Game.

OUR COMMITMENT TO PRIVACY
Your privacy is important to us. In this Privacy Policy, we describe how we collect, use, and disclose information that we obtain about visitors to our website www.honestgame.com (the “Site”), and the users of our application and any related services (the “Services”).  We only collect information from you that we need to provide the Services, we only collect it with your consent and we never sell any data that you provide to us.  We prioritize student data privacy in our work and protect all data through use of industry best practices. 

SINGLE SIGN ON 

Honest Game supports single sign-on to make it easy for your staff and students to log into the Honest Game app. We are partnered with Clever and ClassLink to provide single sign-on via their platforms. Our customers can search for and request to connect with Honest Game via their respective administrative portals. Honest Game users with Google accounts can also use the Sign In With Google button to authenticate via Google OAuth2.

Personal Information We Collect

Information that We Collect About You from Your Educational Institution
When we partner with an educational institution, we collect information directly from a student’s school to interpret a student’s NCAA and NAIA eligibility status and provide an individualized guide for the student to maintain or get on track to eligibility. We will collect the following information: student name, student ID #, specific sport(s), GPA, graduation class, transcript information including grades earned, course names, PSAT/PACT/SAT/ACT scores, student email, parent email and school counselor/coach email. 

Honest Game may obtain the information above from education records created and maintained by your child’s educational agency or institution. When we or a student’s educational agency or institution ask for your permission to disclose educational records to us or another third-party, you will be informed as to what we will do with the information you or your child (depending upon whether you are a parent/guardian or a student over the age of 18) provides us, and how you can review your/your child’s information and ask us to delete the information. With your verifiable consent, we or your/your child’s educational agency or institution may collect other personal information from your child when such information is necessary for use or provision of the Services.

Information We Collect Directly From You
Account Registration:  When you register for Services directly with us, we will collect registration and payment information so that we can provide an account for you.  If you do not need an account but want to register for our events, webinars, or publications, we also collect basic registration information from you.

Service Information:  In order to interpret a student’s NCAA and NAIA eligibility status and provide an individualized guide for the student to maintain or get on track to eligibility, we collect from you and your school:  student name, student ID,  specific sports, graduation class, transcript information including grades earned, course names, SAT/ACT scores, student email, parent email and school counselor contact information.  In some cases, we can work with you to get this information directly from your educational institution. 

Information We Collect Automatically
We may automatically collect the following types of information about your use of our Site and Services through cookies and other technologies, including for example, your browser type and operating system:

• your IP address; information about the device you use to access our Site and Services; how you use the Site and Services; login and logout timestamps, and the length of time you use our Site or Services. We may combine this information with other information that we have collected about you, including, where applicable, your name, and other personal information.

Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

CONTROL OF YOUR INFORMATION
You are entitled to access and review your personal information that we hold. You may terminate your original consent given at any time, terminating the partnership.

If you have accessed our Services through your educational institution, please direct any requests to review or access your information to your school.

THE WAY WE USE INFORMATION
We primarily use the information that we receive to provide data and an individualized plan for you to achieve NCAA and NAIA eligibility and otherwise provide the Services. We do not use students’ information for any other purpose other than as necessary for provision of the Services. We also may use your information to respond to your requests and improve our Site and Services, such as:

• To respond to your inquiries and for other customer service purposes
• To keep your personal information secure and protect our Site and Services (including to verify user identities and prevent fraud and abuse)
• To personalize your experiences while using our Site and Services
• For research, historical, and analytical purposes
• For marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters or to otherwise contact you about products or information we think may interest you. We do not send marketing materials to students.
• To better understand how users access and use our Site both on an aggregated and individualized basis
• As permitted or required by law.

Tracking and Use of Cookies
We and our third-party service providers use cookies and similar technologies to analyze trends to track information about your use of our Site or Services and gather demographic information about our user base as a whole. We may combine this information with other personal information we collect from you (and our third party service providers may do so on our behalf).

You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our websites or service. By continuing to use our Site and Services, you are agreeing to our use of cookies as described in this Policy.

Cookies
Cookies are small files that are placed onto your device (e.g., computer, smartphone or other electronic device) that store information when you visit a website. Pixel tags (also called web beacons, clear gifs, or tags) are a similar technology that consists of small images or snippets of code that can help the website owners learn how you interact with websites and emails. Some cookies allow us to make it easier for you to navigate our Site and Services, to deliver relevant local resources, remember browser preferences, and improve our visitors’ experiences on the site. There are two types of cookies: session and persistent cookies.

• Session Cookies: Session cookies exist only during an online session. They are typically deleted from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site or a Service. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
• Persistent Cookies: Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.
• Disabling Cookies: Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.

Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function. To learn more, visit cookies.

Third Party Analytics
We use automated means to evaluate usage of our Site and Services. We use these tools to help us improve our performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your personal information with these third parties.

• We use Google Analytics on the Site to collect usage data, to analyze how users use the Site and to provide advertisements to you on other websites. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

HOW INFORMATION MAY BE SHARED
Honest Game does not sell your personal information. Honest Game does not share your personal information without your consent except as outlined in this Privacy Policy.

Like many companies, Honest Game may share your information with certain trusted third-party services to help us provide, improve, promote, or protect our services. For example, we may store your data on a third-party data storage service to support delivery of our services. We may also share your data with third-parties to provide services such as processing your payment transactions, improving our Services, or to provide other services. Whenever we share data with such third-party services, we require that they use your information only for the purposes we’ve authorized, and that they protect your personal information at least to the same standards we do. By agreeing to use our Services, you acknowledge that you have been informed via this section as to what we will do with the information you provide.

We also share data in the following ways:

• With your consent, we will share your academic eligibility data with college coaches to improve your chances of being recruited as a college-athlete
• To protect our legal rights and property
• To comply with the law or law enforcement or to comply with a subpoena or court order
• If we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Otherwise, your personal information is never shared with any individual or other organization in a way that is inconsistent with this Policy. 

DATA RETENTION
Honest Game retains personal information as long as is necessary for the purposes set of providing you the Services.  We delete personal student information two months after the student graduates from high school.  We maintain aggregate data on students for research purposes and to improve our Site and Services. When retaining this aggregate (i.e. de-identified data), we remove the student’s name, email, and student/school ID # from all account details.

SECURITY OF MY PERSONAL INFORMATION
The security of your personal data is important to us. We have implemented commercially reasonable and industry standard precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We use AWS SSL as our encryption-based internet security protocol. All sensitive data is encrypted via the AES-256 algorithm. Please be aware that no data security measures can guarantee 100% security.

STORAGE AND ACCESS
Your personal information is stored in and accessed from the United States.

CHILDREN
Honest Game does not knowingly collect any personal information from children under the age of 13, and children under 13 are not permitted to register for or use our services. If we become aware that a child under age 13 has provided us with personally identifiable information, we’ll delete it, unless we have received parental consent.

THIRD PARTY WEBSITES
This policy does not extend to anyone whose personal information is not under our control or management, including data that is collected by other websites that you may visit before or after the Site, which are not governed by this Privacy Policy. We are not responsible for the data protection or privacy policies of any other websites and accept no responsibility or liability for those policies. Please carefully check the policies of other websites and services you use before you visit or submit personal information. 

CALIFORNIA PRIVACY RIGHTS
Under the California Consumer Privacy Act (“CCPA”), California residents have certain rights regarding the personal information that businesses have about them. This includes the right to notice, access and/or deletion of your personal information, as well as the right to direct a business to stop selling your personal information.

• Right to Notice.You have the right to be properly notified of the following:
• Personal Information We Collect: Please review the section of this Privacy Policy titled Personal Information We Collect for more information about the personal information we collected about you in the past 12 months.
• Why We Collect Personal Information: Please review the section of this Privacy Policy titled The Way We Use Personal Informationfor more information on why we collect personal information about you in the past 12 months.
• How We Collect Personal Information: Please review the section of this Privacy Policy titled Personal Information We Collectfor more information on how we collect personal information about you in the past 12 months.
• With Whom We Share Your Personal Information: Please review the section of this Privacy Policy titled How Information May Be Sharedfor more information on how we share personal information about you in the past 12 months.
• Right to Access Your Information: You have the right to request the following covering the 12 months immediately preceding your request:
  • The specific pieces of personal information we have collected about you
  • The categories of personal information that we have collected about you
  • The categories of sources from which we collected the personal information
  • The purpose for collecting or selling the personal information
  • The categories of personal information that we have disclosed about you, the purpose for disclosing such personal information and the categories of third parties with whom we disclosed such personal information
  • The categories of personal information that we have sold about you, as well as the categories of third parties to whom we sold such personal information

Please note that we may still use aggregated and de-identified personal information that does not identify you or any individual.

• Right to Deletion: You have the right to request that we delete any personal information about you that we have collected from you. Please note that there are exceptions where we do not have to fulfil a request to delete information, such as when the deletion of information would create problems with the completion of a transaction or compliance with a legal obligation.

How to Exercise Your Access and Delete Rights: To exercise your access and delete rights as described above, please submit a verifiable consumer request to us by emailing us at [email protected].

Verifiable Consumer Requests: Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access to your personal information twice within a 12-month period. The verifiable consumer request must: 1) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of that person; and 2) Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it. We cannot respond to your request to exercise your access and/or deletion rights if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format: We attempt to respond to a verifiable consumer request within 45 days after we receive it. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing within 45 days after we receive your initial request. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period immediately preceding the date we receive the verifiable consumer request. The response we provide will also provide the reasons we cannot comply with a request, if applicable. For access requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

• Right to Opt-Out of Sale: While we do not sell personal information in exchange for any monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA (Cal. Civ. Code 1798.140(t)(1)). We support the CCPA and wish to provide you with control over how your personal information is collected and shared. If you would like to exercise your right to request opt-out of sale, please submit a request using this link or email us at [email protected].
• Right to Non-Discrimination: We will not discriminate against you (e.g., through denying goods or services, or providing a different level or quality of goods or services) for exercising any of the California rights afforded to you.

Financial Incentives.  We may offer financial incentives, such as providing you discounts to sign up for our mailing list. You may withdraw from these financial incentives at any time by contacting us at [email protected]. The value of your personal information is the value of the offer presented to you. We have calculated the value of the incentive by using the expense related to the offer.

Complaints. In compliance with the CCPA, we commit to resolve complaints about your privacy and our collection or use of your personal information. We ask that you kindly contact us at [email protected], so that we have an opportunity to resolve your complaint.

Do Not Track.  Some internet browsers – like Internet Explorer, Firefox, and Safari – include the ability to transmit “Do Not Track” or “DNT” signals.  Since uniform signals have not been adopted, we do not current process or respond to “Do Not Track” or “DNT” signals.

California’s Shine the Light law. California residents with an established business relationship with us can request information once a year about sharing their personal information with third parties for the third parties’ direct marketing purposes. If you are a California resident and would like to request more information under the California Shine the Light law, you can email us at [email protected]. 

Rights of European Union Residents Under the General Data Protection Regulation (“GDPR”)
Residents of the European Union member countries (Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden) have the following rights vis a vis Honest Game under GDPR:

• Ask us for access to, or correction or erasure, of your data;
• Restrict processing (pending correction or deletion);
• Object to communications or direct marketing; and
• Ask for the transfer of your data electronically to a third party (data portability)

Legal Basis for Processing Your Data Under GDPR
We rely on separate and overlapping bases to process your Personal Information lawfully, including to process a transaction you have requested, to carry out our responsibilities under a contract, or in certain cases to pursue the legitimate interests of Honest Game, where those interests are not overridden by your rights and interests. Honest Game handles your personal data securely and takes proactive measures to minimize its use. We will retain your Personal Information for so long as you maintain a relationship with Honest Game or until you request us to do otherwise. We will publish on our website any changes we make to this data protection statement and notify you by other communication channels where appropriate.

Where you exercise your right to erasure, we will continue to maintain a core set of personal data (name, subject(s), matriculation and graduation details, unique Honest Game identification number, and date of birth) to ensure we do not contact you inadvertently in the future, and to maintain your academic record for archive purposes. We may also need to retain some financial records about you for statutory purposes (e.g. anti-fraud and accounting matters).

INTERNATIONAL USERS
We store personal information about website visitors and subscribers within the United States. As a US-based company, to facilitate our operations, we may transfer and access such personal information from the United States, and other countries where our trusted third-party vendors may reside.

If you are visiting our Site or use our Services from the EEA or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal information to the United States and other jurisdictions in which we operate. By providing your personal information, you consent to any transfer and processing in accordance with this Policy.

HOW TO CONTACT US
If you have questions or comments about this Privacy Policy, or if you are not completely satisfied with this Privacy Policy or its application by us, we invite you to convey your questions, concerns, or suggestions to our Data Privacy Office or write us at:

Attention: Director of Data Privacy and Research
Honest Game Corporation
PO Box 5820
Evanston, IL 60204

Honest Game strives to satisfy our customers’ and visitors’ privacy concerns. We will reply as quickly as possible and inform you of the steps, if any, that have been or will be taken to address your concern or implement the suggestion.

CHANGES TO THIS POLICY
This Policy is current as of the Effective Date set forth above. Privacy laws and practices are constantly developing, and so our policies and procedures are under continual review, and we may change this Policy from time to time, so please be sure to check back periodically. Your continued use of the Site and our Services following the posting of changes to these terms means you accept these changes. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information that we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on this page.