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 in order 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 PBC

PRIVACY POLICY

Effective Date: September 18, 2020

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 PBC.

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.

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 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 will collect the following information: 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.

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 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.

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.

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 PBC 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.

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.

CHILDREN

Honest game PBC 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.

INTERNATIONAL USERS

We store personal information about website visitors and subscribers within the European Economic Area (the “EEA”), the United States, and other countries and territories. 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 PBC 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 in order 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.