PRIVACY POLICY

Effective Date: April 16, 2024

PlayVS takes your privacy very seriously. At Play Versus, Inc (“PlayVS,” “we,” “us,” “our”), we know you care about how your personal information is used and shared, and we take protecting the privacy of our users very seriously. This privacy policy (“Privacy Policy”) explains how your personal information is processed by PlayVS when you visit or use our website, www.playvs.com (our “Website”), and our related software and online or mobile services provided on or in connection with our Website (collectively, our “Service”). By accessing or using our Service, you signify that you have read, understood and agree to our processing of your personal information as described in this Privacy Policy and our Terms of Use. Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

All capitalized terms that are not defined in this Privacy Policy shall have the meaning given to them in the Terms of Use or under applicable law. 

Scholastic Leagues: If you participate in a Scholastic League and use PlayVS in connection with a K-12 school, school district or athletic association (collectively referred to as “Schools”), please refer to Section 7 to learn more about PlayVS protects the privacy of K-12 students. 

California, Colorado, Connecticut, Nevada, Utah, and Virginia residents: Please refer to Section 10 for additional information about our data privacy practices and to understand your rights. 

1. PERSONAL INFORMATION WE PROCESS

Account and athlete profile information:  We process personal information when you create a registered user account, sign up for our mailing list, purchase or register a product, or otherwise communicate with us. The personal information we process during account registration may depend on your account type but could include name, phone number, date of birth, player name, email address, mailing address and other contact information. We may process this information directly from you or it may be provided by the team Coach or other team members. We also process additional information if you provide it in your athlete profile, which could include the name of your team or school (name, city, state), graduation year, photo or avatar, social media handle(s) and esports position. If a user enrolls in a non-PlayVS league offered by a Partner League, we may request additional pieces of personal information if required by the Partner League. If a user enrolls in a competition or league with additional eligibility requirements (such as a collegiate competition or league), we may request additional pieces of personal information to verify your eligibility for participation, such as by verifying your enrollment status in a college or university. 

Communications and payment:  We process personal information when you sign up for our mailing list or otherwise communicate with us, including by contacting us in person (for example, at camps, competitions, conferences, workshops, seminars and other events), via telephone, facsimile or email. We also process payment information if you make a purchase or sign up for a subscription. 

Data processed through the use of the Service: We process information about how you use the Service, your actions on the Service, and any content you post to the Service (“User Content”), as well as information about a player or team record, for example, gameplay statistics, personal or team awards and highlights featuring the team or athlete. 

Information we receive from third parties: We may receive personal information about you from third parties and combine that with the information we process through the Service. For example, we receive information about your activities on third party games you access through the Service. We may also receive information from any third-party services that you link to the Service. For example, if you link your PlayVS account to your account on a social network such as Discord or Twitch, these services will authenticate your identity and may provide some of your personal information to us. The data we receive is dependent on that third party’s policies and your privacy settings on that third-party service.  We will process your authentication token and any personal information the service provides to us in order to provide you with the Service. PlayVS may also allow you to connect your YouTube account to your athlete profile. PlayVS’s use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.

We process this information to operate, maintain, and provide the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages and push notifications, and permit you to communicate with others on the Service or invite others to join the Service. We may also send you Service-related emails or messages (e.g., account verification, change or updates to features of the Service, technical and security notices). For more information about your communication preferences, see “Your Data Rights and Choices” below. 

Usage and Device Information

To provide a personalized and high-quality experience for our users, we may use various technologies that automatically record certain technical information from your browser or device when you visit our Website, read our emails, use our Service or otherwise engage with us. This information is typically processed through a variety of tracking technologies, including cookies, web beacons, file information and similar technology (collectively, “tracking technologies”). These tracking technologies cookies process information about how you use the Service (e.g., the pages you view, the links you click, emails you open, and other actions you take on the Service), information about your browser and online usage patterns (e.g., Internet Protocol (“IP”) address, browser type, browser language, referring / exit pages and URLs, pages viewed, whether you opened an email , links clicked), and information about the device(s) you use to access the Service (e.g., mobile device identifier, mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, and whether you access the Service from multiple devices). We may be able to determine your approximate location by analyzing other information, like an IP address. We may also process analytics data, or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the Service. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout. 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. 

We use or may use the data processed through tracking technologies to secure the Service, improve the Service, to save you time, to provide better technical support, and to track website usage. For example, tracking technologies help us to: (a) remember information so that a user will not have to re-enter it during subsequent visits; (b) provide custom, personalized content and information; (c) to identify you across multiple devices; (d) to provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, and usage on our Website and our Service; (f) diagnose or fix technology problems; (g) help users efficiently access information after signing in, and (h) otherwise to plan for and enhance our Service. 

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it. 

We and our third-party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see “Third-party tracking and online advertising” below.

Lawful Basis for Processing

Many jurisdictions require that we disclose to you the lawful basis for our processing of your personal information. We do that throughout this Privacy Policy. In general, our lawful basis for processing your personal information is based on your specific consent or your contract with us.  

By accessing or using any of the Service or by otherwise interacting with us online, you consent to our processing of your personal information as described in this Privacy Policy. If our processing of your personal information is based on your consent, you may withdraw your consent at any time, and we will cease processing your personal information. However, in some cases, this may result in your inability to receive partial or full access to the Service, and your withdrawal of consent does not limit our ability to use de-identified data for use by us in connection with our legitimate business efforts in the future. In addition, your withdrawal of consent may not prevent us from processing personal information if we have processed such personal information pursuant to a different lawful basis or to preserve legal claims. For example, if you give your consent for us to process your personal information, but we are also required by law to process your personal information, that separate “lawful basis” will still apply, even if you withdraw your consent.

When you enter into an agreement with us, either by registering for and accessing the Service, by executing an agreement in hard copy, or by clicking “I Accept” or similar language online, we will process your personal information for the purposes of fulfilling the terms of our contract with you. In that case, our processing of your personal information is based on the contract, so your withdrawal of consent will only be effective after the purposes for processing that personal information have been fulfilled and after we no longer have a legal obligation to process that personal information.

In all cases, we will comply with applicable law and we will cease processing your personal information after the legal right, obligation, or other lawful basis expires.

2. SHARING OF YOUR INFORMATION

PlayVS takes great care to protect the information you provide us.  PlayVS will disclose your personal information when you post content that is visible to others on the Service, when you consent or instruct us to share your information with third parties, or when we have a legitimate business or legal need to share your information.  We may also disclose de-identified, anonymous, or aggregate information that does not reasonably identify you as an individual.  For example, your information may be shared with: 

The public (Competition Data is visible to others on the Service by default). Like any sports league, some information about athletes and competition results is posted on the Service and will be visible to other users, Website visitors and the public by default when you use the Service (“Competition Data”). Competition Data includes certain personal information from the athlete profile, including athlete player name, full name, photo or avatar, esports position and certain optional athlete profile fields, as well as athlete player statistics and gameplay highlights. Email addresses, payment details, and birth date are not Competition Data and are not available to the general public.

Other authorized users or organizations associated with the athlete’s use of the Service. If you use the Service through an organization enrolled in an enterprise contract or license, authorized administrative users may have access to your entire athlete profile, including if available, email address, phone number and other personal information that is not considered public Competition Data. 

Third party game providers to facilitate game play.  PlayVS facilitates gameplay through third-party game providers. When you or your team, captain or coach elect to participate in a game provided by a third-party game provider, we share certain information, such as an athlete’s player name or player ID, with that third-party game provider to facilitate gameplay on the third-party service. PlayVS takes best efforts to ensure these third parties are in alignment with PlayVS practices, however these third-party game providers use your information according to their own privacy policy and practices, which may differ from the practices described in this Privacy Policy. For example, the third-party game provider may combine the player information shared by PlayVS with information it processes from you directly through gameplay or if you create a personal account on the game provider’s service. Please review the privacy policy of any third-party game provider or service to understand their privacy practices before you participate in any third-party game through the Service. 

Partner Leagues. From time to time, PlayVS may provide access to esports leagues provided by a third party (“Partner League”).  If a user enrolls in a Partner League via the PlayVS service, your information will be shared with the Partner League and will be subject to the Partner League’s own privacy policy. For a full list of third parties and their privacy policies, please click here. Depending on the features and functionality of the Partner League, we may disclose personal information with third-party game providers as required by the Partner League to facilitate Partner League gameplay.

Third Party Partners and Sponsors. From time to time, and in a manner consistent with your preferences or as permitted by law, we may provide your information, including name and email address, to our corporate partners and official sponsors. Our sponsors may use this information to offer you deals, discounts and other promotional content and to communicate with you. You may opt out of any such communications at any time. 

Third parties with your consent or according to your instructions. You may provide consent or authorization to share your personal information with third-party applications or services in several ways, depending on the functionality available now and in the future through the PlayVS Service. Please note that these third parties are not governed by PlayVS or the terms of this Privacy Policy. We recommend you review the privacy policy of any third-party application or service before authorizing access to your PlayVS account information. For example, you may authorize PlayVS to share your information with: 

• Special programs you participate in. If you participate in special programs where PlayVS partners with third parties, PlayVS may share data processed from or about you with its third-party partners to facilitate the program or services being offered. For example, we may share your contact information with third parties with whom we partner to provide contests/sweepstakes, which will usually be identified by name in the Official Rules.
• Others with your consent. In some instances, you may be able to grant us permission to share your information with third-party partners, recruiters, not-for-profit organizations, and other entities that are not affiliated with PlayVS. In these cases, we will only provide to these third parties the information you have authorized or asked us to share to these third parties. You may also choose to share content with others by email, or by posting PlayVS content to social media sites such as Facebook, Twitter, Discord or Twitch.  These third parties may use your information as described in their own privacy policies. To control the information that you share, you can adjust your social network settings or disconnect your social network account from your PlayVS account.

Third parties to verify eligibility.  We may utilize third-party verification services, including enrollment and employment verification services provided by Sheer ID, to confirm eligibility for certain account types (e.g., Coaches) or for participation in a competition or league with additional eligibility criteria. For example, if you wish to participate in a college league, we will share your personal information, including name, date of birth, email address and school name, with Sheer ID to verify your current enrollment status in a college or university. We may ask for additional pieces of personal information as needed to complete the enrollment verification process. 

We may also share information for the following business purposes: 

• Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include providing mailing services, providing payment or accounting services, web hosting, or providing analytic services. 
• Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings. 
• Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of PlayVS, our users, visitors, or others.

We may also share information with others in an aggregated, de-identified, or otherwise anonymized form that does not reasonably identify you directly as an individual. For example, we may use and share de-identified, aggregate, or anonymized data to study and improve our Service, user functionality and product offerings.

3. THIRD PARTY TRACKING AND ONLINE ADVERTISING

PlayVS may participate in interest-based advertising and use third-party advertising partners to process information from visitors to the Service for the purpose of displaying interest-based advertisements on other websites, apps or services, social networks, or on other devices you may use. Typically, though not always, these third-party ad networks use cookies and tracking technologies to recognize your browser or device and to process information about your visit to our Service to provide you customized content, advertising and commercial messages which may be more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. 

Please note that we will our best efforts and take multiple steps to avoid the use of K-12 Student Data (defined in Section 7) for targeted advertising purposes, for example, by inhibiting these third-party advertising networks from processing information for targeted advertising purposes when a K-12 Student athlete logs into the Scholastic League service. Additionally, we do not knowingly direct targeted advertising to individuals we know to be K-12 Students on our Service or on any other website or online service.

To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android).  You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.     

Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.

4. YOUR DATA RIGHTS AND CHOICES

Account information and settings: You may update your account information by editing your profile or signing into the account settings. 

Control email communications: You can opt-out of receiving promotional emails from us by clicking the “unsubscribe” feature at the bottom of each email. Unfortunately, you cannot unsubscribe from Service-related messaging. 

Modifying or deleting your information:  If you have any questions about reviewing, modifying, or deleting your information, or if you want to remove your name or comments from our Website or publicly displayed content, you can contact us directly at privacy@playvs.com.  We may not be able to modify or delete your information in all circumstances.  For instance, we may not be able to delete Competition Data but we may be able to anonymize certain Competition Data upon request.  

If you have any questions or requests about your account information, contact us directly at privacy@playvs.com.

5. HOW WE STORE AND PROTECT OUR INFORMATION

Storage and processing: Your information processed through our Service may be processed in the United States or any other country in which PlayVS or its affiliates or service providers maintain facilities.  If you are located in the European Union or other regions with laws governing data processing 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. PlayVS uses a number of third-party tools to facilitate the delivery of our product and service. A full list of these third parties can be found here. 

Keeping information safe: We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information processed by our Service. Access to information is limited to those employees who require it to perform their job functions. We use industry-standard Secure Socket Layer (SSL) encryption technology to safeguard the account registration process and sign-up information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to building and files. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%.  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 investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

6. LINKS TO OTHER WEB SITES AND SERVICES

The Service may contain links to and from third-party websites of our business 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 policies or content. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they process information.

7. SCHOLASTIC LEAGUES: HOW DOES PLAYVS PROTECT STUDENT DATA AND COMPLY WITH LAWS?

PlayVS is the official school esports league, used by K-12 schools, school districts and athletic associations (collectively referred to as “Schools”) to offer competitive esports activities to K-12 student athletes (“Students”) through the PlayVS Scholastic League. 

We take our commitment to Student privacy very seriously. This Section describes how we process the personal information processed from a K-12 Student when that Student participates in Scholastic League competition as a member of an official Scholastic League School team (“Student Data”). In order to be considered a verified Student athlete, the player must have a school email address on file and be verified as a member of the team by the School admin user with authority over the School team (“Coach”). This Section does not apply to college or university users nor to K-12-aged users associated with unofficial school teams, club teams or unverified teams. Similarly, information associated with a student’s personal account and use of the Service outside of the Scholastic League (including, for example, for club play) will not be considered “Student Data.”

Please note that third-party game providers that Schools may engage with through the Service may have practices and policies that differ from those described herein. The Student Data we disclose to the game provider (e.g. the player name or player ID), as well as any other personal information the game provider processes from the School or its Students directly, will be governed by the game provider’s own privacy policy and the terms of any other agreement between the game provider and the School. Please read the Privacy Policy of any third-party game provider to understand their privacy practices before you participate in a third-party game.

Student Data privacy principles.  We are committed to the following principles to protect Student Data: 

• We process Student Data only to provide and support the Service as described in our Privacy Policy, to maintain, develop, support or improve our websites, services and applications, and as otherwise permitted by our agreements or with the consent of the parent, guardian, student or School.  
• We do not process Student Data for targeted advertising purposes. While we do permit third-party advertising partners to operate on our Service for the purpose of retargeting, analytics and attribution services, we take steps to disable third party ad networks from processing information for targeted advertising purposes within the Scholastic League portions of the Service.
• We do not build a personal profile of a Student other than in furtherance of the School’s use of the Service (for example, athlete profiles and player history are created and displayed as part of the esports competition statistics and history), or as authorized by a Student or parent, for example, if a student transfers information to a personal account.
• We maintain a comprehensive data security program designed to protect the types of Student Data maintained by the Service. 
• We will clearly and transparently disclose our data policies and practices to our users. 
• We will never sell Student Data unless the sale is part of a corporate transaction, such as a merger, acquisition, bankruptcy, or other sale of assets, in which case we will require the new owner to continue to honor the terms provided in this Privacy Policy or we will provide the School with notice and an opportunity to opt-out of the transfer of Student Data by deleting the Student Data before the transfer occurs. 
• We will not make any material changes to our Privacy Policy or contractual agreements that relate to the processing of Student Data without first giving notice to the School and providing a choice before the Student Data are used in a materially different manner than was disclosed when the information was processed.

Information we process in connection with Scholastic Leagues:  In addition to the data processing practices specified in Section 1 of this Privacy Policy, we also process the following information in connection with the Scholastic League service: 

• Information about Schools: We ask for certain information when a School representative registers a School with PlayVS, or if the representative corresponds with us online, including a name, school name, school district, school email address, role at school, phone number, and relevant IT and equipment information required for students to participate on campus. School representatives and coaches may also provide information about students, such as a team roster. We may also process information provided by a School if the School sends us a message, posts content to our Website or through our Service, or responds to emails or surveys. Once a School begins using the PlayVS Service, we will process content and information provided by the School through the School’s use of the Service and we will keep records of activities related to the Service. 
• Information about Students: We process information about Student athletes from the School or from the Student directly, including name, grade or date of birth, school email address, school (name, city, state), and may process additional information associated with the Student’s athlete profile, including the athlete player name, parent/guardian information (name, relation, email and phone), graduation year, photo or avatar, and esports position. We may receive this information directly from the Student or it may be provided by the School or Coach to register for the team. 

How we process and disclose Student Data:  

PLEASE NOTE:  Competition Data, which may contain Student Data, is disclosed to the public by default. Like any school sports league, some information about Student athletes and competition results is posted on the Service and may be visible to other users, Website visitors and others in the form of Competition Data. In addition to other information defined as “Competition Data” in this Privacy Policy, Competition Data includes certain personal information from the Student’s athlete profile, including: Student athlete player name, full name, graduation year, school (name, city, state), photo and/or avatar, and esports position, as well as athlete player statistics and gameplay highlights. Email addresses, phone number, parent or guardian information (name, relation, email and phone), payment details, and birth date are not Competition Data and are not available to the general public. 

Many Schools consider the type of personal information contained in Competition Data to be to be “Directory Data” under FERPA. We rely on Schools or Associations to confirm that Competition Data related to a School and Student athlete may be displayed publicly through the Service in accordance with the School’s definition of Directory Data and/or that the School otherwise has a parent’s or guardian’s consent to display such information publicly. If you do not wish to have a K-12 Student's personal information displayed in Competition Data, please contact PlayVS to determine whether another option may be available.

We also disclose Student Data in the following circumstances: 

• Other authorized users or organizations associated with the K-12 Student athlete’s use of the Service. We disclose personal information between and among other users of the Service associated with the School or team, such as Coaches, team administrators and School representatives, and the school, school district or state association associated with the School or team’s use of the Service. These users will be able to view a K-12 Student’s entire athlete profile, including email and, if available, home address, phone number and parent/guardian information. 
• Third parties game providers authorized by the School or Coach.  PlayVS facilitates gameplay through third-party game providers. When a School or Coach elects to participate in a game provided by a third-party game provider, we share the Student athlete’s player name or player ID with that third-party game provider to facilitate gameplay on the third party service. These third-party game providers process this information according to their own privacy policy and practices, which may differ from the practices described in this PlayVS privacy policy. For example, the third-party game provider may combine the player information shared by PlayVS with information it processes from the Student directly through gameplay or if the Student creates a personal account on the game provider’s service. Schools and team coaches should review the privacy policy of any third-party game provider or service to understand their privacy practices before you participate in any third-party game through the Service. 
• Third Party Partners and Sponsors. From time to time, and in a manner consistent with your preferences or as permitted by law, we may provide our corporate partners and official sponsors information about coaches and adult users, such as a School name, coach name and coach email address. Our sponsors may use this information to offer deals, discounts and other promotional content to Schools and coaches and to otherwise communicate with Schools or coaches.  

We also process and disclose Student Data with the consent or subject to the instructions of the Student, parent or guardian, School or Coach, and as needed for our business purposes, as described in our Privacy Policy under Section 2 “Sharing of Your Information.”  

How we retain and delete Student Data: We do not knowingly retain Student Data beyond the time period required to support the School’s purpose, unless authorized by a School, Student or parent, though we retain Competition Data and gameplay statistics, competition highlights and history indefinitely as part of the official record of the esports competition. 

The School is responsible for maintaining current Student athlete rosters and informing PlayVS to delete or de-identify accounts which the School no longer needs to retain. Unless otherwise directed by a School, Student or parent, we will delete or de-identify personal information contained in K-12 Student accounts in accordance with the terms of any applicable written agreement with the School, written requests from authorized School administrators, and our standard data retention schedule.  

Schools and/or K-12 Students (or their parents) can request account deletion at any time by contacting PlayVS at support@playvs.com. We may not be able to immediately or completely delete all data in all instances, such as information retained in technical support records, customer service records, backups, and other similar business records. 

We will not be required to delete any information which has been de-identified or disassociated with personal identifiers such that the remaining information cannot reasonably be used to identify a particular individual, nor will we be required to delete information that has been transferred to a personal account except at the direction of the athlete or parent.  Please note that we may not be able to delete Competition Data but we may be able to anonymize certain Competition Data upon request.  

Compliance with laws:  We do not use K-12 Student Data for any purpose other than to provide the Service, in accordance with our contractual agreements with the National Federation of State High School Network and its affiliate entities (NFHS), our Terms of Service and this Privacy Policy. Our use of Student Data may also be governed by contractual agreements in place with a State Association, school district, purchasing organization or with a particular School.   PlayVS does not own or control Student Data, which belongs to the Student and/or the School or association that contracts with PlayVS to provide the Service to the K-12 Student.  

The PlayVS Service is designed to provide protections for Student Data as required by applicable privacy laws. For example: 

• The Family Educational Rights and Privacy Act (FERPA).  This Privacy Policy and our Service are designed to meet our responsibilities to protect personal information from the Students' educational records under FERPA. We will work with our School and Association partners to jointly ensure compliance with the FERPA regulations.
• Children’s Online Privacy Protection Act (COPPA).   PlayVS is intended for players and coaches, including children under of the age of 13. PlayVS does not knowingly process any information from children under the age of 13 without parental consent, and PlayVS takes necessary steps to ensure no child information is gathered without parental consent. A child under 13 may have a PlayVS account, but this account may only be created by a parent after providing their consent to provide their child’s information. PlayVS only requires child information that is necessary to deliver the PlayVS service, and PlayVS gives parents full control over their child’s data. Children’s data is never monetized or knowingly used for targeted advertising. PlayVS will delete a child’s information after 10 months of inactivity. Please contact us at privacy@playvs.com if you believe we have inadvertently processed personal information of a child under 13 without proper consent so that we may delete such data as soon as possible.
• FTC's COPPA Safe Harbor Program. Protecting Children’s and student’s privacy is especially important to PlayVS. We participate in the iKeepSafe Safe Harbor program. We have been granted the iKeepSafe COPPA Safe Harbor seal signifying that our playvs.com website and app.playvs.com web application have been reviewed and approved for having policies and practices surrounding the collection, use, maintenance and disclosure of personal information from Children consistent with the iKeepSafe COPPA Safe Harbor program guidelines. COPPA protects the online privacy of Children under the age of 13; please email us about the iKeepSafe Safe Harbor program if you have any concerns or questions at privacy@ikeepsafe.org.
• Students Online Personal Information Protection Act ("SOPIPA"). This Privacy Policy and our Service are designed to comply with SOPIPA. We do not use Student Data for targeted advertising purposes. We do not use processed information to amass a profile of a K-12 Student except in furtherance of providing the features and functionality of the Service. We never sell Student Data unless the sale is part of a corporate transaction, such as a merger, acquisition, bankruptcy, or other sale of assets, in which case we make efforts to ensure the successor entity honors the privacy commitments made in this policy and/or we will notify the School and provide an opportunity to opt-out by deleting Student Data before the data transfer occurs. 
• California Assembly Bill 1584 ("AB 1584"). This Privacy Policy and our Service are designed to comply with AB 1584. Pupil records obtained by PlayVS from a local educational agency ("LEA") continue to be the property of and under the control of the LEA. Parents, legal guardians, or eligible pupils may review personally identifiable information in the pupil's records and correct erroneous information by contacting their LEA directly. In the event of an unauthorized disclosure of a pupil's records, PlayVS will notify the LEA and will provide the LEA with information to be shared with the affected parent(s), legal guardians(s) or eligible pupil(s). Pupil records will be deleted and/or de-identified in accordance with our agreements with each School and as described in this Privacy Policy.
• Connecticut Conn. Gen. Stat. Ann. § 10-234aa-dd.  PlayVS’s Connecticut Addendum to the Terms of Service, available upon request, is designed to comply with the requirements of the Connecticut Act Concerning Student Data Privacy, Conn. Gen. Stat. Ann. § 10-234aa-dd. Please contact us at support@playvs.com to learn more about incorporating the Connecticut Addendum into your agreement with PlayVS.

If you have any questions about our practices with regard to Student Data, please contact us at privacy@playvs.com.