A clear and bold heading
Last Revised: November 22, 2021
This Policy describes:
- The types of information we collect from you or that you may provide when you visit our informational website available at: https://elitegaminglive.com/ (the “Website”), as well as any our website application available at: https://app.elitegaminglive.com/loginUser (“Website Application”, together with the Website, the “Platform”).
- Our practices for collecting, using, maintaining, protecting, and disclosing that information.
Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our Platform. By using our Platform, you agree to the terms of this Policy. This Policy may change from time to time (see below, “Changes to this Policy”). Your continued use of our Platform after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
The Platform turns students’ love of gaming into a meaningful, competitive, and enriching experience. The Platform’s competitions are designed to build social-emotional learning through competition and to introduce students to STEM learning, through EGL Academy. The Platform may be used by schools, school districts, teachers, other school officials (collectively referred to as “Schools”), students and students’ parents or guardians inside and outside of a classroom setting. When the Company enters into a contract with Schools to provide the Platform as part of the School’s educational curriculum, the Company may have access to certain information about students, teachers, or other school officials that use the Platform or create a Platform account. Parents (defined below) may also individually sign up for our Platform and services and not through a School. In this instance, Parents may directly enter into separate agreements with the Company.
This Policy applies to individuals who interact with the Platform, create Platform accounts, and provide us with other user information, including, parents or legal guardians of children and students (“Parents”), Schools, school officials (collectively, with Parents, referred to throughout this Policy as “you” or “your”), and students and children (“Student Users”). This Policy applies to information we collect on the Platform or in emails and other electronic messages between you and the Platform, and information gathered when you interact with our advertising on third-party websites if such advertisements include links to this Policy.
This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Platform (for further information, see below, “Third-party Websites”).
- What We Collect and How We Collect It
To ensure that we provide you and Student Users with the best possible experience, we will store, use, and share personal information about you or a Student User in accordance with this Policy. Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device (“Personal Information”).
In particular, the Platform has collected the following categories of Personal Information from users of the Platform within the last twelve (12) months:
- Financial information
- Protection classification characteristics
- Commercial information
- Internet or other similar network activity
- Geolocation data
- Non-public education information
- Information drawn from other Personal Information
We obtain the categories of Personal Information listed above from the following categories of sources:
- Schools and Parents. For example, from:
- Parents of students;
- Directly from a school;
- Afterschool organizations;
- Other educational institutions; and
- Other users that may provide us information about you or a Student User, such as a school leader providing us student Personal Information.
- Directly from you. For example, when you:
- register yourself or someone else with the Platform;
- request a demonstration;
- subscribe to our services;
- subscribe to one of our e-newsletters;
- review or comment on our services; or
- communicate with us, such as request information.
- Indirectly from you or a Student User. For example, through information we collect from you or a Student User in the course of providing our services to you or a Student User. An example of this is when a Student User provides the Company with their Parent’s email address to sign up for our services. Additional information collected from a Student User may include the games they play and what gaming systems they are playing on.
- Schools and Parents. For example, from:
- Directly and indirectly from activity on our Platform. For example, from Platform usage details that are collected automatically. For more information on automatic information collection, please review the “Automated Information Collection” section below.
The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting the Company to request further information. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our services. Additionally, we may ask you to create a username and password that should only be known to you.
Geolocation Data. We may collect or use precise location data, including the real-time location of fixed location device and IP addresses, in order to provide you with our services.
Student Information. The Company is not an educational institution as defined under the Family Educational Rights and Privacy Act (“FERPA”). However, the Company engages schools to provide services to students of the school and may collect student Personal Information and information that pertains to student performance in school sanctioned activities (“Student Information”). As a result, the Company protects all Student Information with reasonable administrative, technical and physical safeguards, including, where appropriate, agreements with contracted Schools.
Our commitment: Our collection and use of Student Information is governed by our contracts with the Schools, by this Policy, and by applicable privacy laws. For example, we will work with Schools to help protect Student Information, as required by FERPA, whenever applicable, and to protect the Student Information of students under 13 consistent with the Children’s Online Privacy Protection Act (“COPPA”). If you have any questions about reviewing, modifying, or deleting the Student Information of a Student User accessing the Platform through a School partner agreement, please contact your School directly, whom can then contact the Company directly.
- We do not disclose Student Information for targeted advertising purposes.
- We do not build a personal profile of a Student User other than in furtherance of an educational or competitive purpose related to the nature of our service.
- We will clearly and transparently disclose our data policies and practices.
- Automated Information Collection
In addition to the information that you may provide to us, we may also collect information about you or a Student User during your visit to our Platform. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Platform. Some of the tools we use to automatically collect information about you may include:
- Cookies. A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined in one of two ways, and we may use either (or both) of them:
- (1) session cookies, which do not stay on your device after you close your browser, and
- (2) persistent cookies, which remain on your device until you delete them or they expire.
We use the following categories of cookies on our Platform.
- Cookies. A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined in one of two ways, and we may use either (or both) of them:
- Strictly Necessary Cookies. These cookies are essential in order to enable you and Student Users to move around the Platform and use its features. Without these cookies, services you have requested, such as maintaining a record of your purchased items, cannot be provided.
- Performance Cookies. These cookies collect anonymous information on how you and Student Users use our Platform to help us understand how you and Student Users arrive at our Platform, browse or use our Platform and highlight areas where we can improve, such as navigation. The data stored by these cookies never shows personal details from which Student Users or your individual identity can be established.
- Functionality Cookies. These cookies remember choices you and Student Users make such as the country from which you visit our Platform, your preferred language, and your search parameters. This information can then be used to provide you and Student Users with an experience more appropriate to your selections and to make your visits to our Platform more tailored to your preferences. The information in these cookies may be anonymized. These cookies cannot track browsing activity on other websites.
- Targeting Cookies or Advertising Cookies. These cookies collect information about browsing habits in order to make advertising more relevant. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third-party advertising networks. These cookies remember the websites you visit and that information is shared with other parties, such as advertisers.
Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Platform’s features or lose access to some functionality.
- Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of the third-party marketers we engage with may use Web Beacons to track your interaction with online advertising banners on our Platform. This information is only collected in aggregate form and will not be linked to your Personal Information. Please note that any image file on a webpage can act as a Web Beacon.
- Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used by email recipients. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.
- Third-party Websites and Services. We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on our Website and also on the websites where our marketing communications are appearing. For example, we may collect data where our banner advertisements are displayed on third-party websites.
- How We Use Your Information
The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:
- manage leagues;
- providing the information, products and services you request;
- security, credit or fraud prevention purposes;
- providing you with effective customer service;
- providing you and Student Users with a personalized experience when you and Student Users use the Platform;
- contacting you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
- contacting you with information and notices related to your use of the Platform;
- inviting you to participate in surveys and providing feedback to us (in accordance with any privacy preferences you have expressed to us);
- better understanding Student Users’ and your needs and interests;
- improving the content, functionality and usability of the Platform;
- improving our products and services;
- improving our marketing and promotional efforts; and
- any other purpose identified in an applicable privacy notice, click-through agreement or other agreement between you and us.
- How We Share Your Information
We will not disclose or share your, or Student Users’, Personal Information with third parties for the purposes of third-party marketing to you without your prior consent. We do not sell or lease your, or Student Users’, Personal Information to any third party. We may share your, or Student Users’, Personal Information by disclosing it to a third party for a business purpose. When we disclose Personal Information, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract.
We may aggregate or otherwise anonymize the data we collect for purposes of analytics, research, marketing and other business interests of the Company. Such use shall not include Personal Information or information that can identify you or a Student User as an individual or reasonably be used to identify you or a Student User.
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for one or more business purposes:
- Financial information;
- Protected classification characteristics;
- Commercial information;
- Geolocation data;
- Non-public education information; and
- Internet or other network activity information.
We disclose your Personal Information for a business purpose to the following categories of third parties:
- Our affiliates;
- Program partners. If you participate in special programs where we partner with third parties, we may share data collected from or about you or a Student User with our third-party partners to facilitate the program or services being offered. These program partners may use the information we share with them as described in their own privacy policies.
- Third party vendors. Third party vendors who provide services that enhance our Platform, products and services to you and Student Users (such as vendors for credit card processing, advertising and marketing and customer support).
Except as described in this Policy, we will not share your, or Student User, Personal Information with third parties without your notice and consent, unless it is under one of the following circumstances:
- Legal Reasons.
- We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order;
- To respond to duly authorized information requests from law enforcement or other governmental authorities;
- To investigate and prevent security threats, fraud, or other malicious activity; or
- To respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or Company employee.
- Sale of Business or Merger. There are circumstances where the Company may decide to buy, sell, or reorganize its business in selected countries. Additionally, the Company may be involved in a merger, acquisition, bankruptcy or change of control. Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, the Company will ensure your, and Student User, information is used in accordance with this Policy.
- Your Choices and Selecting Your Privacy Preferences
We want to provide you with relevant information that you have requested. When possible, we will provide options as to what information we collect and how you can manage any preferences that pertains to such information.
If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Transactional or service-oriented messages are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.
When you create an account on the Platform, you acknowledge and agree that we may send you marketing emails regarding our products or services. After you receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.
Sponsored Content. The Company does not display any third-party advertisements on the Platform. Sponsored content will always be labeled (e.g., “Sponsored by ___”). The Company will not share any of your, or Student Users’, Personal Information with these sponsors without notice, and these sponsors do not have the ability to track or collect information about Platform visitors or Student Users. You may opt out from such sharing by contacting the Company at email@example.com. Please note: From time to time, the Platform may display YouTube video content created by third parties and not by the Company. While internally created video content does not display video advertisements, third party content may include advertising which the Company cannot control.
- Text Messaging
Any such communications you receive from us will be administered in accordance with your preferences and this Policy.
- Accuracy and Access to Your Personal Information
We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing.
Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security. We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.
Update or Delete Personal Information. Parents, school leaders, team coaches, and other school officials can request Personal Information and account deletion on our Platform. Such a request can be made by contacting the Company directly at firstname.lastname@example.org. We will then verify the authenticity of the Parent, school leader, team coach, or other school official contact via communicating with the School.
We may not be able to delete Personal Information in all instances. We will not be required to delete any Personal Information which has been de-identified or disassociated with personal identifiers such that it can no longer be used to reasonably identify a particular individual.
Unless we receive a deletion request, we will retain your Personal Information for as long as your account is active or as is reasonably useful for operational purposes. For example, we may retain certain Personal Information as necessary to prevent fraud or future abuse, for recordkeeping or other legitimate business purposes, or if required by law. We may also retain Personal Information which has been de-identified or aggregated such that it can no longer reasonably identify a particular individual. All retained Personal Information will remain subject to the terms of this Policy.
- Information of Minors
We do not collect Personal Information directly from individuals under the age of 13. We will only obtain the Personal Information of individuals under the age of 13 either from a Parent or from a School. By providing information of an individual under the age of 13, the Parent or School represents to Company that it is doing so knowingly and in accordance with all lawful consent and authorization under applicable law. We encourage Parents to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we are aware of any Personal Information that we have collected about children without the proper consents, we will take steps to securely remove it from our systems.
- Submissions, Profiles and Message Boards
- Third-party Websites
- Your California Rights
Shine the Light law. Pursuant to California Civil Code Section 1798.83, we will not disclose or share your, or Student User, Personal Information with third parties for the purposes of third-party marketing to you or Student Users without your prior consent.
Do Not Track Signals. Other than as disclosed in this Policy, the Website does not track users over time and across third-party websites to provide targeted advertising. Therefore, the Website does not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser.
WE DO NOT SELL YOUR, OR STUDENT USER, PERSONAL INFORMATION. If we ever decide to sell Personal Information, we will update you via this Policy and include a link entitled “Do Not Sell My Personal Information,” to provide you with an opportunity to opt out of sales of your Personal Information.
California Consumer Rights. If you are a California consumer, as defined by the California Consumer Privacy Act of 2018 (“Act”), please be advised that EliteGamingLive, Inc. does not currently meet the regulatory thresholds of a “business” as that term is defined under the Act and therefore is not required to comply with the Act. Regardless, all Personal Information will be processed in accordance with this Policy.
- For Platform Users Outside of the United States
Our Platform is designed for use by individuals in Canada and the United States only. We do not warrant or represent that this Policy or the Platform’s use of your Personal Information complies with the laws of any other jurisdiction. Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.
- Safeguarding the Information We Collect
We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password. If you believe your credentials have been compromised, please change your password. Please also notify us of any unauthorized use.
- Changes to this Policy
The Company may update or change this Policy from time to time in order to reflect changes in any offered services, changes in the law, or for other reasons as deemed necessary by the Company. If we make any changes to this Policy, a revised Policy will be posted on this webpage or screen and the date of the change will be reported in the “Last Revised” block above.
- How to Contact Us
We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us by email at email@example.com or by reaching out to your regional program director directly.