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
Effective Date: November 24, 2021
OUR COMMITMENT TO PRIVACY
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:
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:
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.
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
HOW INFORMATION MAY BE SHARED
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:
Otherwise, your personal information is never shared with any individual or other organization in a way that is inconsistent with this Policy.
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.
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
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.
Please note that we may still use aggregated and de-identified personal information that does not identify you or any individual.
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.
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:
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).
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
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.