Privacy Policy

Purpose of this Privacy Policy

Thank you for trusting us with your information. We are committed to protecting your information while you conduct business on the Internet, telephone or in person.

This privacy policy (the “Policy”) describes the manner in which Tilton School (“SCHOOL”) and Gameonstream Inc. (“GOS”) collect, use, retain, safeguard, disclose and dispose of the personal information of all subscribers and other users of the Website and Services as well as the images (still, video and other) of all individuals appearing in Content including all athletes, coaches and other team officials, referees, volunteers and spectators.

For purposes of this Policy, the terms “Website”, “Services” and “Content” shall have the meanings ascribed to them in the Terms and Conditions of Use (“Terms of Use”) found at https://tilton.gameonstream.com/pages/privacy_policy.

Overview of Policy

This Policy will explain to you the kinds of information we collect from you, why we collect such information and how we utilize it.  Specific questions we address include:

  • What kind of data do we collect from you?
  • Why do we collect this data?
  • How do we obtain your data?
  • How long is your personal information retained?
  • How is your personal information secured?
  • Do we share your personal information with third parties? If so, why?
  • What are cookies and how do we use cookies?

Our commitment to you includes our compliance with and adherence to applicable laws and policies governing our collection and use of your personal information including PIPEDA (the Personal Information Protection and Electronic Document Act) (Canada), the General Data Protection Regulation (GDPR) (European Union) and Privacy Shield frameworks (U.S. and Switzerland).

Accordingly, this Policy also explains your principal rights under such data protection laws with respect to the collection of your personal information, including your rights:

  • to access your personal information;
  • to rectify your personal information;
  • to erase your personal information;
  • to restrict processing of your personal information;
  • to object to processing of your personal information;
  • to portability of your personal information;
  • to complain to a supervisory authority about our collection and use of your personal information; and
  • to withdraw consent to the collection of your personal information.

What is Personally Identifiable Information (“PII”)?

  • Personally Identifiable Information (“PII”), also known as “personal information” or “personal data”, means any information relating to an “identified or identifiable natural person”. An “identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Why Do We Collect PII from You?

We collect your PII for program registration, purchases of goods and services (if available through your program) and transfer of necessary information to certain third parties, and to:

  1. Verify your identity;
  2. Deliver requested products and services (where applicable);
  3. Contact you utilizing emails or newsletters or other methods;
  4. Enhance your user experience; and,
  5. Improve our internal processes.

We also may utilize your PII to contact you for the purpose of:

  1. Order confirmations;
  2. Important updates about your order; and,
  3. Troubleshooting and query resolution.

How Do We Collect PII?

We collect your PII through telephone calls, by utilizing web forms and through third party applications that may transfer the information to us.  We also may use cookies or similar technologies to collect PII, or generate snapshots of the browser tab to assist in error resolution.

Information SCHOOL and GOS Collects

We collect information in two ways:

  • Information you give us. For example, to access all the Services you will be required to obtain a SCHOOL and GOS When you do, we’ll ask for personal information, such as your name, email address, telephone number and/or credit card details.
  • Information we get from your use of the Website and/or Services, including your Support requests and interaction. We may collect information about the Services that you use and how you use them.  This information includes:
  • Device information

We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number).  SCHOOL and GOS may associate your device identifiers or phone number with your SCHOOL and GOS Account.

  • Log information

When you use the Services or view Content, we may automatically collect and store certain information in server logs. This may include:

  • details of how you used the Services.
  • Internet Protocol (IP)
  • device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
  • cookies that may uniquely identify your browser or your SCHOO Land GOS
  • Unique application numbers

If any Service includes a unique application number, this number and information about your installation (for example, the operating system type and application version number) may be sent to SCHOOL and GOS when you install or uninstall that Service or when that Service periodically contacts our servers, such as for automatic updates.

  • Local storage

We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage and application data caches.

  • Cookies and anonymous identifiers

We use various technologies to collect and store information when you visit the Website and/or access the Services, and this may include sending one or more cookies or anonymous identifiers to your device.

  • Support Request Information

We collect telephone log information such as your phone number, calling-party number, forwarding numbers, time and date of calls, duration of calls, SMS routing information and types of calls.

How We Use Information We Collect

We use the information we collect from the Website and Services to provide, maintain, protect and improve the Services, to develop new services and functions, and to protect SCHOOL and GOS and our users. 

When you contact SCHOOL and GOS, we may keep a record of your communication to help resolve any issues you might have.  We may use your email address to inform you about the Services, such as letting you know about upcoming changes or improvements.

We use information collected from cookies and other technologies, like pixel tags, to improve your user experience and the overall quality of the Services.

We will ask for your consent before using PII for a purpose other than those that are set out in this Policy.

SCHOOL and GOS may process your PII on a server located outside the country where you live.

Use of Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide web services and functionalities for the users.

Cookies may be either "persistent" cookies or "session" cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date).  A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Don't Want to Accept Cookies?

If you do not want to accept cookies you should end your browsing on this site or change the cookie setting in your browser.  Most web browsers allow control of cookies through the browser settings.

Accessing, Updating and Erasing Your Personal Information

You have the right to know whether your PII is included in our databases and, if so, to confirm that such PII is accurate and relevant for the purposes for which we collected it. Upon reasonable request by email, to us (at [EMAIL ADDRESS]), you may review your PII stored in our databases and, as permitted by applicable law and our policies, correct, erase, or block any data that is incorrect. You also may edit your PII by logging into your account profile. In making modifications to your PII, you must provide only truthful, complete and accurate information. To request deletion of PII, you must submit a written request to us at [EMAIL ADDRESS].

Requests for PII

Unless prohibited by law or regulatory order, we will provide notice to the appropriate parties when either of the following circumstances arise: (a) a legally binding request for disclosure of PII is made by a government authority (unless we are prohibited by law or regulation from providing such notice); or (b) requests received from you (i.e., the owner of the PII). If we receives a request by you to access your PII, we will provide you such access, unless prohibited by law.

Satisfying Requests for Access, Modifications, and Corrections

We will endeavor to respond in a timely manner to all reasonable written requests by you to view, modify, or delete your PII.

Information We Share

We do not share PII with companies, organizations and individuals outside of SCHOOL and GOS unless one of the following circumstances applies:

  • With your consent

We will share PII with companies, organizations and/or individuals outside of SCHOOL and GOS when we have your consent to do so.  We require opt-in consent for the sharing of any PII.

  • With domain administrators

If your SCHOOL and GOS subscription is managed for you by a domain administrator then your domain administrator and resellers who provide user support to your organization will have access to your SCHOOL and GOS subscription information (including your email and other data).  Your domain administrator may be able to:

  • view statistics regarding your account.
  • change your subscription password.
  • suspend or terminate your access to the Services.
  • access or retain information stored as part of your subscription.
  • receive your subscription information in order to satisfy applicable law, regulation, legal process or enforceable governmental request.
  • restrict your ability to delete or edit information or privacy settings.

Please refer to your domain administrator’s privacy policy for more information.

  • For external processing

We provide personal information to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Policy and any other appropriate confidentiality and security measures.

  • For legal reasons

We will share personal information with companies, organizations or individuals outside of SCHOOL and GOS if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

  • meet any applicable law, regulation, legal process or enforceable governmental request.
  • enforce applicable Terms of Use, including investigation of potential violations.
  • detect, prevent, or otherwise address fraud, security or technical issues.
  • protect against ha rm to the rights, property or safety of SCHOOL and GOS, our users or the public as required or permitted by law.

We may share aggregated, non-personally identifiable information publicly and with our partners – like publishers, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of the Services.

In addition, financial transactions relating to the Website and/or Services are handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your transactions, providing refunds where appropriate and dealing with complaints and queries relating to such transactions and refunds.

If SCHOOL and GOS are involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any PII and give affected users notice before PII is transferred or becomes subject to a different privacy policy.

Information Security

We work hard to protect SCHOOL and GOS and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. In particular:

  • We encrypt many of our services using SSL.
  • We offer you verification when you access your SCHOOL and GOS
  • We regularly review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
  • We restrict access to personal information to SCHOOL and GOS employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

While we endeavor to protect and secure the PII provided to us through the Website, data transmissions over the internet are always subject to some risk of unauthorized access or disclosure. As a result, we do not warrant the security of PII provided to it through the Website and visitors assume all risks associated with the transmission of that PII.

Limited Collection, Use, Disclosure and Retention

We limit the collection, use and disclosure of PII to those purposes we have identified in this Policy.

In addition, all of our employees and contractors are obligated to sign non-disclosure agreements prohibiting use or disclosure of PII except as required to perform their employment/contracting duties.

We retain PII as required under applicable laws. If no statutorily prescribed retention period applies, we will retain PII only for as long as necessary to meet its intended purposes.  Once any prescribed retention period expires, or if we otherwise no longer are required to retain PII to fulfil its intended purpose, such PII is either destroyed or rendered anonymous, in a manner intended to prevent disclosure.

Application

Our Policy applies to the Website and Services and any other services offered now or in the future by SCHOOL and GOS.

Our Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you in search results, sites that may include the Website and/or Services, or other sites linked from ours.  Our Policy does not cover the information practices of other companies and organizations who advertise the Website and/or Services and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

 

Enforcement and Dispute Resolution

We are committed to resolve your concerns about your privacy and our collection or use of your PII.

If your question or concern cannot be satisfied through interaction with us via email, we have further committed to refer unresolved privacy complaints to an independent dispute resolution mechanism administered by the Council of Better Business Bureaus.

If you do not receive timely acknowledgement by us of your complaint, or if your complaint is not satisfactorily addressed by us, individuals residing in the EU may bring a complaint before the BBB EU Online Privacy Shield. Information about how to file a complaint before the BBB EU Privacy Shield program can be found at: www.bbb.org/EU-privacy-shield/for-eu-consumers/. Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism. In Canada, you may register a complaint through the Office of the Privacy Commissioner of Canada at this link: https://www.priv.gc.ca/en/report-a-concern/. In the United States issues can be raised to the Federal Trade Commission: https://ftccomplaintassistant.gov/#&panel1-1.

Alternatively, under the GDPR, if you reside in any EU Member State and are concerned that we is mishandling your personal data, or that any other of your rights under the GDPR have been violated, you may lodge a complaint with the lead supervisory authority of the Member State in which you live (i.e., the independent public authority established by your Member State further to GDPR Article 51).

Complaints and Questions

We will respond to complaints or questions about our compliance with this Policy and with governing legislation. We will investigate and attempt to resolve all issues.

If you have any questions or concerns about your privacy and our role in protecting it, or any other questions about this policy, please contact us by email at [email protected].

Changes

This Policy may be amended from time to time, consistent with PIPEDA, GDPR, the Privacy Shield or Swiss Safe Harbor principles and other applicable data protection and privacy laws and principles.  We will provide notice of any such amendments by posting such changes to our Website, intranet, through email and/or by other means.  We will notify customers if we make changes that materially affect the way we handle previously collected PII, and we will enable customers to choose whether their PII may be used in any materially different manner.

We respect your privacy and its protection is of the utmost importance to us.

We hope you find this Policy helpful and informative.


Dated:  August 21, 2018