LAST UPDATED: 7/19/2022
We care deeply about privacy, particularly when it comes to our student users. High School Esports, Inc. doing business as Generation Esports (“GenE”), and our respective affiliates, subsidiaries, and related corporate entities (collectively, “we,” “us,” and “our”), together with our third-party partners (“Partners”) are committed to being transparent about our privacy practices, including how we collect, process, store, and disclose your personal information in connection with your use of any of the services we provide in connection with your use of our platforms (together, our “Services”), in particular with respect to the Services we provide to students (“Students”) and Users participating in the GenE program through www.highschoolesportsleague.com (the “HSEL Website”), the Middle School Esports League through www.middleschoolesports.com (The “MSEL Website”), or Generation Esports through www.generationesports.com.
Personal Information Collected or Received
Disclosure of Your Information
Third Party Tracking and Advertising
Storing and Securing Your Information
Your Privacy Rights
Your California Privacy Rights
GenE is working to provide an esports platform to service scholastic institutions, communities, brands, personalities, and non-profits with the intent to create fair and fun competition for all participants.
2. PERSONAL INFORMATION COLLECTED OR RECEIVED
In the course of providing our Services, we and/or our Partners may collect personal information about you in a few different ways. For instance, we collect personal information during registration, which may vary based on your account type and whether you are a User, Student, School official, Parent, or Team Administrator.
When registering with us, you are required to choose a password. Other registration information may include the following: name, phone number, email address, School (name, city, state), high school graduation date, age, gender identity, Discord or game ID. We also collect information indirectly from you based on your use of our Services and from our Partners and other third-parties that help us provide Services and with whom you may interact with, such as third party games you access through our Services or third party communities.
Below are some additional details about the information we may collect:
User Registration: GenE collects certain information from all registered users directly including the user’s name, email, zip code, phone number, and GamerTag. This information may be shared with third party Communities on our platform when you opt-in to share your information to them directly through the platform.
School or Club Registration and Account Setup: GenE collects certain information when a School official or Team Admin registers a School with GenE, including the official’s name, School name, School address, telephone number, School email address, position at School, and information related to the computers, software, hardware, and other IT equipment required for facilitating esports at the School. School officials and Team Admins may also disclose information about Students, such as club members and team rosters. We may also collect information if a School official corresponds with us via telephone, email, or social media; shares content to our Website or through our Services; or replies to GenE emails or surveys.
Student Registration and Account Setup: GenE may collect information about Students from their School or from the Student directly, including the Student’s name, email address, School (name, city, state), and graduation date. We may collect additional optional information associated with the Student’s User Profile, including GamerTag, parent/guardian information (name, relation, e-mail, and phone), phone number, grades, gender, photo or avatar, and esports team position. You may directly provide this information to HSEL, or a School official may provide it to us during the team registration process. We refer to personal information collected from or about Students, as well as Student-generated user content, and other information associated with that personal information, as “Student Data.”
Parent/Guardian Account Setup: For students under the age of 13 that wish to participate in HSEL Tournaments, a parent or guardian must sign up on their behalf (“Parent Account”). We do not allow Students under the age of 13 to create an account on our platform. HSEL collects certain information about Parents/Guardians, including their name, email, phone, School (name, city, state), and current grade of their participating student. A participating Student’s GamerTag may be requested and/or required for participation in specific games. No personally identifying data will be collected on the participating Student when under the age of 13. Parent/Guardian user information and other information associated with this data is referred to as, “Parent Data.”
Data Collected Via Service Usage: In order to provide you with our Services, we need to collect, store, and use various information about your activity on our platforms and the use of our Services. For instance, we gather information about your use of the Services, your interaction with the Services, and any content you post to the Services (“User Content”). This User Content may also include win-loss records for Students and School teams; match and tournament statistics; scholarships, awards, and prizes received by Students and/or School Teams; and gameplay highlights featuring Students and/or School teams.
Information Received from Third Parties: We may on occasion obtain personal information about you, including information about Students and Schools from third parties, which is then merged with the information we collect through our Services. For instance, we receive information about your activities from third party game providers you access through our Service. We rely on this information to provide our Services, as well as to enhance their features and functionality. This information all helps us communicate with you, which may include sending you email messages and SMS messages about upcoming matches, allowing you to communicate with other users on our Services, and disseminating Service-related alerts (e.g., account verification requests, feature updates regarding the Service, and technical /security advisories).
Automated Information: To deliver an individualized user experience and keep our Services secure, we may automatically receive and record certain technical information from your browser or device when you interact with us, such as visiting our various websites, reading our electronic messages, and accessing our Services. We may rely on various tracking technologies, such as cookies, web beacons, file information, and similar technology (collectively, “tracking technologies”), to facilitate data collection.
Tracking technologies collect various types of information, including how you interact with our Services (i.e., the pages you visit and the links you click), your browser and online usage patterns (i.e., the browser you are using and your IP address), the device(s) you use to access the Services (i.e., what type of device you are using and its mobile device identifier), and information about your location (i.e., your IP address may be used to associate your account with your School).
3. DISCLOSURE OF YOUR INFORMATION
We respect your privacy. We don’t sell or rent your personal information to third parties for marketing purposes without your express authorization. We may, however, disclose your personal information to our Partners or otherwise when:
You have consented to the processing, which can be revoked at any time;
Disclosure is necessary to comply with a legal obligation, a court order, or to exercise or defend any impending or asserted legal claims;
Disclosure is necessary to further our legitimate interests, as well as those of our third-party business partners;
The information is already public; or
Disclosure is necessary in the public interest, such as to prevent crime or to protect your vital interests or those of others.
More specifically, your information may be shared under the following circumstances:
Public Dissemination of Tournament Data: We post certain information about the results of our tournaments, known as “Tournament Data,” on our Services. This Tournament Data may be visible to other authorized users, website visitors, and the public. Tournament Data includes certain personal information from Player Profiles, including the player’s full name, GamerTag, graduation date, school (name, city, state), photo or avatar, and esports team position, as well as player statistics and gameplay highlights, which will be available publicly on the Service by default when you participate in the Service. Email addresses, parent or guardian information (name, relation, email, and phone), and payment information are not considered Tournament Data and are not available to the general public.
Other Authorized Service Users on The HSEL Platform: We may share personal information with other authorized users of the Service such as club administrators, coaches, and School officials, as well as any school district or state association related to the School’s use of the Service. These users may view a Student’s Player Profile, including email address and, if available, phone number and parent/guardian information.
Affiliated Businesses: We may periodically provide our corporate Partners and official sponsors with information about you, including Student Data, Parent Data and/or User Content as well as information about School officials and other adult users, such as a School name, School official name, and School official email address. Our Partners and sponsors may use this information to offer deals, discounts, and other promotional content to you and or Schools.
Third Party Applications/Services: You may give us permission to share your personal information with third party applications or services that are available (or will be available) via our Service. For instance, you may authorize us to share your information with recruiters, corporate partners, not-for-profit organizations, and other third parties that are affiliated with us. When we share information with these entities, we will only disclose the information that you have authorized or asked us to share. You can also opt to share content with others by email, SMS message, or by posting content from our Services to social media sites, like Facebook or Twitter. These third parties will treat your information in accordance with their own privacy policies, so we encourage you to review such policies prior to authorizing disclosure of your information.
Our Service Providers: We rely on third-party vendors, contractors, and other service providers to perform services on our behalf, which may include sending emails, processing payments, and providing web hosting and analytic services. These third parties may only use your information to perform these tasks on our behalf and are subject to reasonable confidentiality terms.
Aggregated Information: We may also share information with third parties in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual. This aggregate or anonymized data may be used to evaluate and improve our Service, product functionality, and service offerings.
4. THIRD PARTY TRACKING AND ADVERTISING
Please be advised that we will use our best efforts to prevent the use of Student Data for targeted advertising purposes. The steps we take include inhibiting these third party advertising networks from collecting information for targeted advertising purposes when a Student logs into our Services and preventing targeted advertising from being knowingly directed to individuals we know to be Students on our Services or on any other website or online service.
5. STORING AND SECURING YOUR INFORMATION
Storage and Processing: Your information collected through our Services may be stored and processed in the United States or any other country in which we or our affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.
Data Security: The security of your information is important to us. We rely on physical, administrative, and technological procedures to assure the security, integrity, and accuracy of all personal information we collect. We conduct periodic risk assessments and work to remediate any identified security and privacy vulnerabilities in a timely manner. We also restrict employee access to personal information to only those who require it to perform their job functions.
We employ industry-standard security measures, such as Secure Socket Layer (SSL) encryption technology, to safeguard information provided to us during the account registration process. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to building and files.
Although we make good faith efforts to maintain the security of all Personal Information, and in particular Student Data, we can’t guarantee that it will remain free from unauthorized access, use, disclosure, or alteration. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to promptly investigate the situation. In the event that Student Data is accessed or obtained by an unauthorized individual, we will notify impacted Students and Schools within ten (10) days of the incident, or as otherwise required in compliance with any applicable laws and regulations.
6. YOUR PRIVACY RIGHTS
State and federal privacy laws provide users with certain rights related to their personal information. Consistent with applicable laws, we give you the option to access, change, and delete certain information, as well as determine how we communicate with you.
Updating or Correcting Account Information: You have the right to request that we rectify inaccurate information about you. You may update your account information by editing your profile or signing into the account settings.
Modifying or Deleting Information: You have the right to request the deletion of your personal information. We may not, however, be able to modify or delete your information in all circumstances. For instance, we may not be able to delete Tournament Data, but we may be able to anonymize certain Tournament Data upon request.
Accessing Your Information: You can access certain personal information associated with your account by visiting your account privacy settings. You can also request a copy of your personal information from us, as well as information explaining how that information is used. If you would like to review your information or have any questions about changing, or deleting your information, please contact us at firstname.lastname@example.org.
Withdrawing Consent: Where we rely on consent to process your information, you can choose to withdraw your consent at any time using specific features provided to enable you to withdraw consent, such as an email unsubscribe link or your account privacy preferences. By utilizing our Services, to the extent permitted by applicable laws, we will assume you have given your consent to disclose your personal information including, without limitation, Student Data, Parent Data and/or User Content as provided herein.
7. STUDENT DATA
HSEL collects information about Students who use the Service to compete in esports competitions. As previously described herein, the Student Data we collect through HSEL may include the Student’s name, email address, School (name, city, state), and graduation date. Students may also opt to provide additional information in connection with their User Profile, including GamerTag, parent/guardian information (name, relation, e-mail, and phone), grade, phone number, gender, photo or avatar, and esports team position.
HSEL allows Students to save or maintain control over information associated with a Student account by establishing or converting the account to a personal account on the Service or by transferring, sharing or linking such information to a personal account. Information associated with a Student’s personal account will not be considered “Student Data.”
We understand that Parents and Schools are concerned about the privacy of their Students. We are too. HSEL is committed to the following principles to protect Student Data:
No Student Profiling: HSEL does not create personal profiles of Students other than in furtherance of the School’s use of the Service (e.g., Player Profiles and player history are created and displayed as part of the esports tournament statistics and history), or as authorized by a Student or Parent, such as when a student transfers information to a personal account.
Strong Data Security: We maintain adequate data security measures, consistent with industry standards and technology best practices, to protect Student Data from unauthorized disclosure or acquisition by an unauthorized person. In the event that Student Data is accessed or obtained by an unauthorized individual, HSEL will provide prompt notification to all impacted users.
Commitment to Legal Compliance: HSEL is committed to full compliance with all applicable privacy laws, including the Federal Educational Rights and Privacy Act ("FERPA"), 20 U.S.C. 1232g and 34 CFR Part 99, Children's Online Privacy Protection Act ("COPPA"), 15 U.S.C. 6501-6502; Protection of Pupil Rights Amendment ("PPRA") 20 U.S.C. 1232h; the Individuals with Disabilities Education Act ("IDEA").
The type of personal information contained in our Tournament Data may be considered “Directory Data” under FERPA. Accordingly, Schools must confirm that any Tournament Data related to their School and Student esports competitors may be shared publicly through our Services in accordance with your School’s definition of Directory Data and/or that you otherwise have a parent or guardian’s consent to display such information publicly. If you do not wish to have any Student Data displayed in our Tournament Data, please contact HSEL at email@example.com to discuss your options.
Retention and Deletion of Student Data: We do not knowingly store Student Data longer than required to provide our Services, unless authorized by a School, Student, or Parent. However, we retain Tournament Data and gameplay statistics, tournament highlights and history indefinitely as part of the official record of the esports competition.
Schools are obligated to keep their Student rosters current and request that HSEL delete or de-identify accounts that the School no longer needs to retain. Unless otherwise directed by a School, Student, Parent, we will delete or de-identify personal information contained in Student accounts in accordance with the terms of any applicable written agreement with the School and our standard data retention schedule.
Schools, Students, and Parents are entitled to delete their accounts at any time by contacting HSEL at firstname.lastname@example.org. Some data, such as information retained in technical support records, customer service records, backups, and other similar business records, may not be immediately deleted or be able to be deleted completely. HSEL may retain any information that has been de-identified or disassociated with personal identifiers such that the remaining information cannot reasonably be used to identify a particular individual. HSEL will also not delete Student information that has been transferred to a personal account except at the direction of the Student or Parent. Although we may not be able to delete Tournament Data, it may be possible to anonymize certain Tournament Data upon request.
8. LEGAL COMPLIANCE
Please be advised that our Services may contain links to and from third party websites of our Partners (such as gaming providers), advertisers, social media sites, and other services. If you follow a link to any of these websites, please note that these websites have their own privacy policies, and we do not accept any responsibility or liability for their privacy policies or content.
HSEL uses Student Data for the sole purpose of providing our Services, in accordance with all relevant contractual agreements. We do not own or control Student Data, which belongs to the Student and/or the School that contracts with HSEL to provide our Services to the Student.
As set forth in our agreements with Schools, our Services are designed to provide protections for Student Data as required by applicable privacy laws, which include:
The Family Educational Rights and Privacy Act (“FERPA”): Our Service, along with the data protection policies set forth herein, are designed to satisfy our obligation to protect personal information from Students’ educational records under FERPA. We commit to working with Schools to satisfy all compliance obligations under FERPA.
Connecticut Act Concerning Student Data Privacy: In compliance with the requirements of the Connecticut Act Concerning Student Data Privacy, Conn. Gen. Stat. Ann. § 10-234aa-dd, HSEL has developed a terms-of-service addendum. Please contact us at email@example.com to find out about incorporating the Connecticut Addendum into your agreement with HSEL.
9. YOUR CALIFORNIA PRIVACY RIGHTS
California‘s “Shine the Light” law (Civil Code Section §1798.83) entitles California residents that have an established business relationship with us to request certain information regarding personal information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please contact us at firstname.lastname@example.org.
In accordance with the CCPA, California residents may request disclosure of the specific pieces and/or categories of personal information that HSEL has collected about them, the categories of sources for that personal information, the business or commercial purposes for collecting the information, the categories of personal information that we have disclosed, and the categories of third parties with which the information was shared.
HSEL does not sell personal information to third parties for monetary value. However, to the extent that HSEL’s data processing is construed to involve the “sale” of personal information (as that term is broadly defined under the CCPA), California residents are entitled to opt-out of the “sale” of data at any time.
Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser at this time.
10. CONTACT US