Athlon, Inc.  Privacy Policy

This Privacy Policy describes how Athlon, Inc. (“Athlon”), a Delaware corporation that develops interactive technology designed to support movement and wellness, processes information when you access or use our websites at www.athlon.fun and www.letsrallee.com, our mobile applications, online services, and other websites, applications, or experiences that link to this Privacy Policy (collectively, the “Services”).

By accessing or using the Services, you acknowledge the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the applicable Services.

Athlon is committed to protecting the privacy of students and educators and to complying with applicable student and children's privacy laws, including the Children's Online Privacy Protection Act (“COPPA”) and the Family Educational Rights and Privacy Act (“FERPA”), as applicable to Athlon's Services. Athlon has designed the student portion of the Services to minimize the processing of information that directly identifies Student Users and applies additional privacy protections to Student User information as described in the “Children’s Privacy” section below.

Users of the Services may include students who access the student portion of the Services through an Educational Institution (“Student Users”); educators who use the Services in connection with their Educational Institution and may access applicable administrative or reporting functionality (“Teacher Users”); and authorized employees, administrators, or contractors of Educational Institutions, such as principals or district administrators (“School Users”).

The Services may also be used by parents, legal guardians, and other adults independently from a Student Account, as further described in the “Parents, Guardians and Other Adult Users” section of this Privacy Policy.

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Overview

Our approach to privacy is guided by the following principles:

• We design our Services with privacy, security, and data minimization in mind.

• We do not sell personal information.

• We limit the information associated with Student Users that we process to what is reasonably necessary to provide, secure, support, evaluate, and improve the Services and fulfill school-authorized purposes.

• We do not use Student User information for behavioral or targeted advertising or to market products or services directly to Student Users.

• We do not use Student User information obtained through an Educational Institution to identify or obtain contact information for a Student User’s parent or family for marketing purposes.

• We provide users with applicable choices and rights regarding their information as described in this Privacy Policy.

• We apply additional protections to Student User information, including limiting student-facing functionality that would permit Student Users to publicly post or disclose directly identifying contact information through the Services.

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Athlon Website Visitors

Like many website operators, when someone visits our website at www.letsrallee.com or any other site which references this Privacy Policy, whether they use our Services or not, we collect information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. We also collect Internet Protocol (IP) addresses and mobile device ID. Our purpose in collecting such information is to understand better how visitors use our website.

Athlon Accounts and Users

How we collect, use, and disclose information depends on the type of account and the type of user. We currently have three types of accounts: 1) School Accounts; 2) Teacher Accounts; and 3) Student Accounts.

• School Accounts (“School Accounts”, and together with Teacher Accounts, an “Account”) are only for use by schools, school districts, or other licensed educational institutions or programs (each, an “Educational Institution”);

• Teacher Accounts are for use by educators from Educational Institutions with School Accounts (“Teacher Accounts”);

• “Student Accounts” are for use by elementary, middle and high school students of any age, and can only be created, provisioned, or authorized by a School User or Teacher User in conjunction with an Account.

When the primary account is a School Account, Teacher Accounts and Student Accounts will be populated in coordination with the Educational Institution responsible for the School Account and will be considered “Sub-Accounts” of the School Account. Teacher Users and Student Users will be provided access to the Services in accordance with the policies and procedures of their Educational Institution, including through school-provided login credentials or a single sign-on, rostering, or account provisioning provider selected or authorized by the Educational Institution. 

Athlon has designed the Services to minimize the collection of information that directly identifies Student Users. Athlon does not require Student Users to provide Athlon with their name, personal email address, home address, telephone number, date of birth, or other directly identifying contact information to use the student portion of the Services.

When necessary to authenticate a Student User, provision access, maintain the operation of the Services, or associate usage with the appropriate Educational Institution, Athlon may receive or generate a unique identifier or other technical identifier. Athlon uses such identifiers only as reasonably necessary to provide, secure, maintain, support, and improve the Services and for other school-authorized educational purposes described in this Privacy Policy.

Athlon may support single sign-on, rostering, or account provisioning providers selected or authorized by an Educational Institution to facilitate access to the Services. Information processed by those providers is also subject to the applicable provider's terms and privacy practices. Providers currently supported in connection with Student User access to the Services are described in the “Providers Supporting Student Access and Services” section below.

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Authorization by Educational Institutions

​Student Accounts made available through an Educational Institution cannot be independently created by a Student User. Student Accounts must be created, provisioned, or authorized through the applicable Educational Institution in accordance with the account and access procedures described in this Privacy Policy. If Athlon determines that a Student Account has been created or accessed without authorization from the applicable Educational Institution, Athlon may suspend or discontinue access to that Student Account.

Where permitted by applicable law, including COPPA, an Educational Institution may act on behalf of a parent or legal guardian to authorize Athlon to process information associated with Student Users when the Services are provided for the use and benefit of the Educational Institution and for school-authorized educational purposes.

Athlon relies on the applicable Educational Institution to authorize Student User access to the Services and to provide or obtain any notices, permissions, or consents required for the Educational Institution’s use of the Services, consistent with applicable law and the Educational Institution’s agreement with Athlon.

Athlon provides Educational Institutions with information regarding Athlon’s practices concerning Student User information so that Educational Institutions can evaluate the Services and provide or obtain applicable notices, permissions, or consents.

An Educational Institution’s authorization applies only to the use of information associated with Student Users for the school-authorized Services and educational purposes described in this Privacy Policy. Athlon does not rely on an Educational Institution’s authorization to use such information for behavioral or targeted advertising, to market products or services to Student Users or their families, or for other commercial purposes unrelated to providing the school-authorized Services.

Educational Institutions may contact Athlon at info@letsrallee.com to request information regarding Athlon’s Student User information practices or to exercise applicable rights concerning Student User information.

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Collection of Information

Information that Users Provide to Us:

Athlon may process information that users provide when using the Services, including when creating or accessing an account, contacting Athlon with a question, comment, or request, or otherwise interacting with the Services. Information associated with Student Users is processed as described in the “Children’s Privacy” section of this Privacy Policy.

Athlon seeks to minimize the information it processes and limits its processing to information reasonably necessary for the purposes described in this Privacy Policy.

Users may provide information to Athlon in the following circumstances:

• When registering for or accessing an account: School Users and Teacher Users may be requested to provide information reasonably necessary to establish and administer their accounts, such as their school-provided email address, name of class(es) or grade(s) they teach. School Users will also need to provide the email addresses of Teacher users who will be accessing the Services through their School Account. Student Users may use school-provided login credentials to access the Services.” This removes the missing “in,” removes the legacy Platform term, and better matches the SSO/provisioning language we've established elsewhere. Student Users are not required to provide Athlon with their name, personal email address, home address, telephone number, date of birth, or other directly identifying contact information in order to use the student portion of the Services. Student access may instead be provisioned through an Educational Institution or through a single sign-on, rostering or account provisioning provider selected or authorized by the Educational Institution. Athlon intentionally limits the Student User information it collects to the information reasonably necessary to operate, secure, support, evaluate, and improve the Services and to provide the Services for the educational purposes authorized by the applicable Educational Institution.

• When making payments: If a user, Educational Institution, or other organization makes a payment to Athlon in connection with the Services, Athlon may process or receive information necessary to administer the transaction. Payments may be made through financial institutions or payment processing service providers, which may process payment or financial information in accordance with their own privacy practices. Athlon does not retain complete payment card information.

• Voluntarily: School Users and Teacher Users may choose to provide additional information through a separate password protected section of the Services that allows them to administer their accounts and Sub-Accounts, including adding Teacher Users, Student Users, and reviewing Student User and Teacher User data.

Information Collected Automatically:

We and our service providers may automatically collect limited technical and usage information when users interact with the Services. For Student Users, this information may include information about use of the Services and gameplay mechanics, such as whether or when a session occurred, session duration, type of activity or session, activity commencement and completion, interactions with game features, rewards or achievements earned within the Services, and similar product usage information. Athlon does not use this gameplay and usage information for the purpose of independently identifying a Student User by name. Student usage information may be associated with a unique or technical identifier where reasonably necessary to operate the Services, maintain continuity within the product, provide school-authorized functionality, maintain security, measure usage, troubleshoot technical issues, or improve the Services. Athlon may also aggregate or de-identify Student User information so that it is not reasonably capable of being associated with an identified child. Athlon may use aggregated or de-identified information for purposes such as evaluating use of the Services, measuring engagement and effectiveness, improving product features, conducting research and analysis, and reporting aggregate results. 

The third party service providers we use include:

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GOOGLE ANALYTICS (GOOGLE INC.)

Athlon may use Google Analytics to help understand the use and operation of the Services. Google Analytics may process limited technical and usage information in connection with the Services. Athlon limits the use of Google Analytics in connection with Student Users to purposes reasonably necessary to analyze, maintain, support, and improve the Services and does not authorize the use of Student User information processed through Google Analytics for behavioral or targeted advertising. 

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FIREBASE (GOOGLE INC.)

Firebase is a technology platform provided by Google that Athlon may use to support certain technical functions of the Services, such as application infrastructure, analytics, performance monitoring, authentication, or other operational functionality. Athlon does not use Firebase to collect or store a Student User’s name, personal email address, home address, telephone number, or other directly identifying contact information for the purpose of operating the student portion of the Services. Student usage and technical information processed through Firebase may instead be associated with a unique or technical identifier. Athlon limits the use of Student User information processed through its service providers to purposes necessary to provide, secure, maintain, support, analyze, or improve the Services and for other school-authorized educational purposes.

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How We Use The Information Collected

Athlon may use information processed in connection with the Services for the purposes described below and elsewhere in this Privacy Policy. Athlon may engage service providers to process information on Athlon’s behalf where reasonably necessary to support these purposes.

Athlon does not use Student User information for behavioral or targeted advertising or to market products or services directly to Student Users. Information associated with Student Users is used as further described in the “Children’s Privacy” section of this Privacy Policy.

The uses described in this section apply as appropriate based on the type of user and the context in which the information is provided or processed. Additional limitations and protections applicable to Student User information are described further in the “Children’s Privacy” section of this Privacy Policy.

• Marketing and Communications: Athlon may use contact information voluntarily provided by Teacher Users, School Users, parents, legal guardians, and other adults to provide information about Athlon and the Services, including product updates, newsletters, events, offers, and other marketing or promotional communications, where requested or consented to by the recipient or otherwise permitted by applicable law. Recipients may unsubscribe from Athlon marketing communications at any time using the unsubscribe mechanism included in the communication or by contacting Athlon as described in the “Contact Us” section of this Privacy Policy. Athlon does not use Student User information obtained through an Educational Institution to identify or obtain contact information for a Student User’s parent or family for marketing purposes.

• Providing and Supporting the Services: Athlon may use information to provide, operate, maintain, secure, support, and troubleshoot the Services; administer accounts and access; process or administer payments where applicable; respond to questions, requests, or support inquiries; provide training or other service-related communications; and provide functionality requested or authorized by users or Educational Institutions.

• Additional Services and Activities: Athlon may use information to allow users to participate in optional surveys, research, programs, events, promotions, or other activities. Where an activity involves additional information practices not otherwise described in this Privacy Policy, Athlon may provide additional notice at the time of participation.

• Analytics and Improvement: Athlon may use information to understand how the Services are used, evaluate the performance and engagement of the Services, conduct analytics, troubleshoot technical issues, develop and improve features and functionality, and measure the effectiveness of the Services. Athlon may use aggregated or de-identified information for analytics, research, measurement, reporting, product development, and improvement of the Services as further described in this Privacy Policy. Uses of Student User information for these purposes are subject to the additional limitations and protections described in the “Children’s Privacy” section of this Privacy Policy.

• Security, Legal Compliance, and Enforcement: Athlon may use information as reasonably necessary to protect the security, integrity, and availability of the Services; detect, investigate, or prevent fraud, misuse, abuse, or security incidents; enforce applicable agreements; comply with applicable law, legal process, or requests from governmental authorities; and protect the rights, safety, or property of Athlon, our users, Educational Institutions, or others.
   

What Student User Information Can Other Users See?

Student User information is not publicly available through the Services. Access to Student User information within an Educational Institution is limited based on the roles, permissions, rosters, schools, classrooms, or other access parameters established or authorized by the Educational Institution. This may include information such as the date or time of a recent session, session or activity type, number of sessions or activities completed, activity completion, rewards or achievements earned within the Services, and similar usage or gameplay information. Student names or other identifying roster information displayed to authorized Teacher Users are provided, provisioned, or otherwise made available through the Educational Institution or its authorized rostering, single sign-on, or account provisioning process. Athlon does not require Student Users to provide this identifying information directly to Athlon in order to use the student portion of the Services.

School Users may have access to information across multiple classrooms, schools, buildings, or other organizational groups based on the roles and permissions established or authorized by their Educational Institution. The scope of information available to each School User or Teacher User is determined by the applicable account configuration, roster, and access permissions established or authorized by the Educational Institution. Athlon does not make Student User information publicly available and does not permit Teacher Users or School Users to access Student User information outside the scope authorized by their Educational Institution. Athlon may share or make Student User information available to the applicable Educational Institution, or at the direction of the Educational Institution, as necessary to provide the Services and consistent with Athlon’s agreement with the Educational Institution, this Privacy Policy, and applicable law.

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How We Share your Information

Athlon may disclose information in the circumstances described below and elsewhere in this Privacy Policy. The information disclosed and the purpose of the disclosure depend on the type of user, the context in which the information was provided or processed, and the Services involved. Additional limitations and protections applicable to Student User information are described in the “Children’s Privacy” section of this Privacy Policy.

Athlon does not sell personal information. Athlon does not disclose Student User information for behavioral or targeted advertising or to market products or services directly to Student Users.

Service Providers: Athlon may disclose information to service providers that process information on Athlon’s behalf or provide services supporting Athlon or the Services, such as hosting, infrastructure, authentication, analytics, communications, support, security, and payment processing. Athlon limits information disclosed to service providers to information reasonably necessary for the applicable services or purposes.

Legal, Security, and Safety Purposes: Athlon may disclose information where reasonably necessary to comply with applicable law, legal process, or requests from governmental authorities; protect the security or integrity of the Services; investigate or prevent fraud, misuse, abuse, or security incidents; enforce applicable agreements; or protect the rights, safety, or property of Athlon, our users, Educational Institutions, or others.

Educational Institutions: Athlon may make Student User information available to the applicable Educational Institution and its authorized School Users and Teacher Users as necessary to provide the Services and school-authorized functionality. Access to Student User information within an Educational Institution is subject to the roles, rosters, organizational structure, and permissions established or authorized by the applicable Educational Institution, as further described in this Privacy Policy.

Combined, Aggregated, and De-Identified Information: Athlon may combine information processed through different portions of the Services where reasonably necessary to provide, maintain, support, evaluate, and improve the Services and for other purposes described in this Privacy Policy. Athlon may also aggregate or de-identify information so that it is not reasonably capable of being associated with an identified individual or, in the case of Student User information, an identified child. Athlon may use aggregated or de-identified information for legitimate business purposes, including analytics, research, measurement, reporting, product development, and improvement of the Services. Athlon does not use Student User information obtained through an Educational Institution to create advertising profiles or to identify or obtain contact information for a Student User’s parent or family for marketing purposes.

At Your Direction or With Your Consent: Athlon may disclose information to another person or organization when you direct Athlon to do so, affirmatively consent to the disclosure, or request a service or experience that involves the disclosure.

Corporate Transactions: Athlon may disclose or transfer information in connection with an actual or proposed merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar corporate transaction, subject to applicable law and the protections described in this Privacy Policy.

How to Access, Change, or Delete Account Information

​School Users can review or change the information they provided when registering for the Services by accessing the appropriate dashboard within the Services, and may request that we provide for their review, or delete from our records, any personally identifiable information they have provided about themselves, or about Student Users associated with their Account, or to cease collecting personally identifiable information from those, as applicable, by contacting us as described in the Section titled “Contact Us” below. 

Teacher Users, Parents and Student Users must request access to, changes and deletions of their Student User’s information or Student Account information by contacting the teacher or Educational Institution that established the Student Account.

Please keep in mind that a request to delete personally identifiable information may lead to the cancellation of an account. When we change or delete any personally identifiable information at your request, we will make good faith efforts to make the changes in our then active databases so that the personally identifiable information will no longer be used in our active databases as soon as reasonably practicable. Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules.

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Account Cancelation and Reactivation, Data Retention

Cancellation, reactivation, and deletion of a School Account and its Sub-Accounts are subject to the terms of the applicable agreement between Athlon and the Educational Institution. 

Accessing and Updating Account Information: Users with an Account may be able to review or update certain Account information through the Services or by contacting Athlon. For Accounts provided through an Educational Institution, requests relating to account information or Student User information may also be directed to the applicable Educational Institution. Additional rights applicable to Student User information are described in the “Children’s Privacy” section of this Privacy Policy.

Account Cancellation or Discontinuation: Users may contact Athlon regarding cancellation or discontinuation of an Account. Where an Account is provided through an Educational Institution, access may also be discontinued at the direction of or in coordination with the applicable Educational Institution. Cancellation or discontinuation of an Account does not necessarily result in the immediate deletion of all information associated with the Account. Athlon retains or deletes information in accordance with the “Retention and Deletion of Student User Information” section of this Privacy Policy, where applicable, and Athlon’s other legal, contractual, security, and operational requirements.

For Student Accounts provided through an Educational Institution, requests concerning access to, correction of, deletion of, or discontinuation of processing of Student User information may be submitted to the applicable Educational Institution or Athlon, as further described in the “School Authorization; Parent Access, Correction, Deletion, and Revocation” section of this Privacy Policy.

Athlon retains information for as long as reasonably necessary for the purposes for which it was processed, including to provide and support the Services, comply with applicable legal or contractual requirements, resolve disputes, maintain security, and enforce applicable agreements. Retention periods may vary depending on the type of information, the Services involved, and applicable legal, contractual, security, and operational requirements. Information may remain in backups or other systems for a limited period following deletion where reasonably necessary for security, continuity, legal compliance, or other legitimate operational purposes. 

Following cancellation or discontinuation of an Account, Athlon may retain and use aggregated or de-identified information that is not reasonably capable of being associated with an identified individual for purposes such as analytics, research, measurement, reporting, product development, administrative purposes, and improvement of the Services, subject to applicable law and this Privacy Policy.

Information associated with Student Users is retained and deleted as described in the “Retention and Deletion of Student User Information” section of this Privacy Policy.
 

Your Choices About Your Information

Email: You may stop receiving promotional email communications from Athlon by using the unsubscribe mechanism included in the communication. Athlon will process unsubscribe requests in accordance with applicable law. You may continue to receive non-promotional communications that are necessary to provide or administer the Services, such as account, technical, security, or other service-related communications. If you have questions about email communications or unsubscribing, you may contact Athlon as described in the “Contact Us” section of this Privacy Policy.

Cookies and Similar Technologies: Athlon may use cookies and similar technologies in connection with certain portions of the Services to provide functionality, maintain security, remember preferences, understand usage, and improve the Services. The technologies used may vary depending on the portion of the Services being accessed and the type of user.

Athlon does not use Student User information for behavioral or targeted advertising and does not use cookies or similar technologies in the student portion of the Services for the purpose of building advertising profiles about Student Users or serving behavioral or targeted advertisements to Student Users.

Depending on the Services and device or browser used, users may be able to manage certain cookies or similar technologies through their browser or device settings or through controls made available by Athlon. Disabling certain technologies may affect the availability or functionality of portions of the Services.

Analytics: Athlon may use analytics technologies to help understand how certain portions of the Services are used and to maintain, evaluate, and improve the Services. Additional information about Athlon’s use of Google Analytics and other analytics service providers is described elsewhere in this Privacy Policy. Where available, users may manage certain analytics technologies through browser or device settings or through controls provided by the applicable service provider.

Children’s Privacy

The Children’s Online Privacy Protection Act and its implementing rules (collectively, “COPPA”) establish requirements relating to the online collection, use, and disclosure of personal information from children under the age of 13. This section describes Athlon’s practices with respect to Student Users under the age of 13 and the rights of their parents and legal guardians. Where permitted by COPPA, an Educational Institution may authorize Athlon to process information associated with Student Users on behalf of parents or legal guardians when the Services are provided for the use and benefit of the Educational Institution and for school-authorized educational purposes.

Student Accounts made available through an Educational Institution cannot be independently created by a Student User. Student Accounts must be created, provisioned, or authorized through the applicable Educational Institution in accordance with the account and access procedures described in this Privacy Policy. If Athlon determines that a Student Account has been created or accessed without authorization from the applicable Educational Institution, Athlon may suspend or discontinue access to that Student Account.

Athlon limits the information processed in connection with Student Users to information reasonably necessary to provide, secure, maintain, support, evaluate, and improve the Services and to provide the Services for school-authorized educational purposes. Athlon does not require Student Users to provide Athlon with their name, personal email address, home address, telephone number, date of birth, or other directly identifying contact information to use the student portion of the Services. Additional details about information processed in connection with Student Users are described elsewhere in this Privacy Policy.

If you believe Athlon has processed information associated with a child under the age of 13 outside the scope of authorization or consent required by applicable law, please contact Athlon as described in the “Contact Us” section of this Privacy Policy.

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Information We Process in Connection with Student Users

Student Users may access the student portion of the Services through an account created, provisioned, or authorized by their Educational Institution. Athlon has designed the student portion of the Services to minimize the processing of information that directly identifies Student Users and limits the processing of Student User information to what is reasonably necessary to provide, secure, maintain, support, evaluate, and improve the Services and for school-authorized educational purposes.

Athlon does not condition a Student User’s participation in an activity on the disclosure of more information than is reasonably necessary to participate in that activity or use the applicable functionality of the Services.

Information Provided or Made Available in Connection with Student Access

Athlon has designed the student portion of the Services so that Student Users are not required to provide Athlon directly with their name, personal email address, home address, telephone number, date of birth, or other directly identifying contact information in order to use the student portion of the Services.

Student access may be created, provisioned, or authorized through the Student User’s Educational Institution or through a single sign-on, rostering, or account provisioning provider selected or authorized by the Educational Institution. In connection with providing the Services, Athlon may process limited information associated with the Student User’s Educational Institution, school, class, grade level, or other authorized group, as well as a unique or technical identifier where reasonably necessary to authenticate or provision access, associate usage with the appropriate Educational Institution or authorized group, maintain continuity within the Services, or otherwise provide the school-authorized functionality of the Services.

Athlon does not request that Student Users provide additional directly identifying contact information in order to participate in gameplay or other student activities within the Services.

Information Collected Automatically

When Student Users interact with the Services, limited technical, usage, and gameplay information may be collected automatically by Athlon or its service providers where reasonably necessary to operate, secure, maintain, support, evaluate, and improve the Services and to provide school-authorized functionality.

This information may include session date or time, session duration, activity or session type, activity commencement and completion, interactions with game features, rewards or achievements earned within the Services, technical performance information, and similar usage information.

Student usage and gameplay information may be associated with a unique or technical identifier where reasonably necessary to authenticate or provision access, associate usage with the appropriate Educational Institution, school, class, grade level, or other authorized group, maintain continuity within the Services, provide authorized Educational Institutions with applicable usage information or reporting, maintain security, troubleshoot technical issues, or otherwise provide the Services.

Athlon does not use Student User gameplay or usage information for behavioral or targeted advertising, to create advertising or marketing profiles about Student Users, or to market products or services directly to Student Users.

Athlon may aggregate or de-identify Student User information so that it is not reasonably capable of being associated with an identified child. Athlon may use aggregated or de-identified information for purposes consistent with this Privacy Policy, including analytics, research, product development, measurement of engagement and effectiveness, reporting, and improvement of the Services.

How We Use Student User Information

Athlon uses Student User information only as reasonably necessary to provide the Services and for school-authorized educational purposes, including to: 

• provide, operate, maintain, and support the Services;

• authenticate or facilitate authorized access to the Services;

• provide gameplay, activities, rewards, progress, and other product functionality;

• maintain continuity of a Student User’s experience within the Services where applicable;

• associate usage with the appropriate Educational Institution, school, class, grade level, or other authorized group;

• provide authorized Teacher Users, School Users, and Educational Institutions with applicable usage information and reporting;

• maintain the security, integrity, reliability, and technical performance of the Services;

• prevent fraud, abuse, and unauthorized access;

• troubleshoot technical issues and provide support;

• evaluate usage, engagement, functionality, and performance of the Services;

• develop, maintain, and improve the Services; and

• comply with applicable law and Athlon’s agreements with Educational Institutions.

Athlon does not use Student User information to serve behavioral or targeted advertising to Student Users, create advertising or marketing profiles about Student Users, sell Student User information, or market Athlon’s or another party’s products or services directly to Student Users.

Athlon does not use Student User information processed in connection with an Educational Institution to market to a Student User’s parent or family. Any parent, guardian, or other adult who elects to receive marketing communications from Athlon must separately provide their own contact information and make the applicable marketing choice outside of the Student User’s school account.

Athlon may aggregate or de-identify Student User information so that it is not reasonably capable of being associated with an identified child. Athlon may use such aggregated or de-identified information for purposes consistent with this Privacy Policy, including analytics, research, product development, measurement of engagement and effectiveness, reporting, and improvement of the Services.

Our Practices for Disclosing Student User Information

Athlon does not disclose Student User information for behavioral or targeted advertising, to create advertising or marketing profiles about Student Users, to market products or services directly to Student Users, or for other commercial purposes unrelated to providing the Services or school-authorized educational purposes. Athlon does not use or disclose Student User information processed in connection with an Educational Institution to identify or obtain contact information for a Student User’s parent or family for marketing purposes.

Athlon may disclose or make Student User information available only as reasonably necessary in the following circumstances:

• Educational Institutions and Authorized School Users: Athlon may make limited Student User information available to the Educational Institution that created, provisioned, or authorized the Student User’s access to the Services and to Teacher Users and School Users authorized by that Educational Institution. Access is limited based on the roles, permissions, rosters, schools, classrooms, buildings, or other access parameters established or authorized by the Educational Institution, as described in this Privacy Policy.

• Service Providers: Athlon may permit service providers to process limited Student User information on Athlon’s behalf only to the extent reasonably necessary for them to provide those services. These may include providers supporting hosting, infrastructure, authentication, single sign-on or rostering integrations, analytics, application performance, security, technical support, or similar operations of the Services. Athlon requires service providers that process Student User information on its behalf to use such information only for authorized purposes and subject to applicable contractual, confidentiality, security, and privacy requirements.

• At the Direction of an Educational Institution: Athlon may disclose Student User information to a provider or other recipient at the direction or with the authorization of the applicable Educational Institution where reasonably necessary to provide the Services and where consistent with applicable law, Athlon’s agreement with the Educational Institution, and this Privacy Policy.

• Aggregated and De-Identified Information: Athlon may use or disclose information that has been aggregated or de-identified so that it is not reasonably capable of being associated with an identified child. Athlon may use or disclose such information for purposes consistent with this Privacy Policy, including analytics, research, product development, measurement of engagement and effectiveness, reporting, and improvement of the Services.

• Legal, Safety, and Security Purposes: Athlon may disclose Student User information when reasonably necessary to comply with applicable law, legal process, court order, subpoena, or a valid governmental or regulatory request; to protect the rights, property, or safety of Athlon, Student Users, Educational Institutions, or others; to protect the security and integrity of the Services; to investigate or prevent fraud, abuse, unauthorized access, or other unlawful activity; or where otherwise permitted or required by law.

• Business Transactions: If Athlon is involved in a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar corporate transaction, information maintained by Athlon may be transferred as part of that transaction, subject to applicable law, this Privacy Policy, and any contractual restrictions or obligations applicable to Student User information.

School Authorization; Parent Access, Correction, Deletion, and Revocation

Where permitted by applicable law, including COPPA, an Educational Institution may authorize Athlon to process Student User information on behalf of parents or guardians when the Services are used for a school-authorized educational purpose and not for an unrelated commercial purpose. Athlon relies on the applicable Educational Institution to provide or obtain any notices, authorizations, or consents required for the Educational Institution’s use of the Services, consistent with applicable law and the Educational Institution’s agreement with Athlon.

Athlon uses information associated with Student Users only as reasonably necessary to provide the Services and fulfill the school-authorized educational purposes authorized or directed by the applicable Educational Institution, as described in this Privacy Policy. Athlon does not rely on an Educational Institution’s authorization to use Student User information for behavioral or targeted advertising, to market products or services to Student Users or their families, or for other commercial purposes unrelated to providing the school-authorized Services.

A parent or legal guardian may request to review, correct, or delete information maintained about their child, or request that further collection or use of their child’s information cease, as provided by applicable law. Because Student Accounts are created, provisioned, or authorized through an Educational Institution, parents and legal guardians may submit such requests to the applicable Educational Institution or Teacher User.

Parents and legal guardians may also contact Athlon at info@letsrallee.com with questions or requests concerning Student User information including requests concerning access, correction, deletion, or discontinuation of processing, as applicable. Where appropriate, Athlon may coordinate with the applicable Educational Institution to verify the request, confirm the requester’s authority with respect to the Student User, and respond to or fulfill the request in accordance with applicable law and Athlon’s agreement with the Educational Institution.

If authorization for a Student User’s continued use of the Services is withdrawn or Athlon is instructed by the applicable Educational Institution to discontinue the Student User’s access, Athlon will discontinue the Student User’s access and further processing of information associated with that Student User as required by applicable law. Any information maintained by Athlon will be deleted or retained in accordance with applicable legal requirements, Athlon’s agreement with the Educational Institution, and the data retention provisions of this Privacy Policy.

Retention and Deletion of Student User Information

Athlon retains information associated with Student Users only for as long as reasonably necessary to provide the Services, fulfill the school-authorized purposes for which the information is processed, comply with applicable legal or contractual requirements, maintain the security and integrity of the Services, or as otherwise permitted by applicable law.

When information associated with a Student User is no longer reasonably necessary for the purpose for which it was processed, Athlon will delete or de-identify the information in accordance with its applicable retention practices, legal obligations, and agreements with Educational Institutions.

If a Student User’s access to the Services is discontinued, Athlon will delete or de-identify information maintained by Athlon that identifies or is reasonably capable of being associated with an identified child when it is no longer reasonably necessary for the purposes for which it was processed, subject to applicable legal or contractual requirements. Athlon may retain aggregated or de-identified information that is not reasonably capable of being associated with an identified child, as well as limited technical or security information where reasonably necessary to comply with applicable law or contractual requirements, resolve disputes, maintain security, prevent fraud or abuse, or otherwise fulfill legitimate obligations associated with the Services.

Aggregated or de-identified information that is not reasonably capable of being associated with an identified child may be retained and used for purposes consistent with this Privacy Policy, including analytics, research, product development, measurement, reporting, and improvement of the Services.
 

Providers Supporting Student Access and Services

Athlon and Educational Institutions may use certain service providers to facilitate authorized Student User access to and use of the Services. Depending on the systems selected or authorized by the applicable Educational Institution and the functionality enabled, these providers may process limited information associated with Student Users for purposes such as authentication, single sign-on, rostering, account provisioning, or facilitating the processing or exchange of information authorized by the Educational Institution in connection with the Services.

Educational Institution-Selected or Authorized Providers

Educational Institutions may select or authorize providers to facilitate Student User authentication, single sign-on, rostering, or account provisioning. Providers currently supported by Athlon may include:

• Edlink

• Google Classroom

• ClassLink

• Clever

The particular provider used for a Student User is selected or authorized by the applicable Educational Institution and depends on the systems used by that Educational Institution. Parents or legal guardians who would like to know which provider is used in connection with their Student User’s access to the Services should contact their Educational Institution.

Information processed through these providers is subject to the applicable provider’s privacy practices and the Educational Institution’s relationship with that provider. Athlon does not determine the Educational Institution’s independent privacy practices or its selection, configuration, or administration of these systems.

Athlon Service Providers

Athlon also uses service providers to perform limited technical functions necessary to provide, secure, maintain, support, analyze, and improve the Services. These providers may support functions such as application infrastructure, analytics, application performance, security, and other technical operations.

Where an Athlon service provider processes information associated with Student Users on Athlon's behalf, Athlon limits such processing to purposes reasonably necessary for the provider to perform its services for Athlon and subjects the provider to applicable contractual, confidentiality, security, and privacy requirements.

Athlon does not authorize its service providers to use Student User information processed on Athlon's behalf for behavioral or targeted advertising or to market products or services to Student Users or their families.

Athlon's current service providers supporting the student portion of the Services include:

• Firebase (Google INC.) - application infrastructure and related technical functionality.

• Google Analytics (Google INC.) - analytics regarding use and operation of the Services.

Athlon may update the providers used to support the Services from time to time. For current information about providers used in connection with the student portion of the Services, or for questions regarding this Privacy Policy or information associated with a Student User, please contact Athlon as described in the “Contact Us” section below.

Parents, Guardians and Other Adult Users

Parents, guardians, and other adults may interact with certain portions of the Services independently from a Student Account, including through family experiences, promotional experiences, events, websites, or experiences offered in connection with Athlon’s partners.

When an adult voluntarily provides information through these experiences, Athlon may process information such as the adult’s name, email address, and other information the adult chooses to provide. Athlon may use this information to provide the experience or information requested by the adult and for other purposes described at the time the information is provided and in this Privacy Policy.

Information voluntarily provided by a parent, guardian, or other adult through an adult-facing experience is separate from Student User information processed in connection with an Educational Institution. Athlon does not use Student User information obtained through an Educational Institution to identify or obtain contact information for a Student User’s parent or family for marketing purposes.

Where an adult is offered the opportunity to receive marketing or promotional communications from Athlon, the adult may elect whether to receive those communications at the time the information is provided.

Athlon may use contact information voluntarily provided by an adult to send marketing or promotional communications where the adult has elected to receive such communications or where otherwise permitted by applicable law. Adults may unsubscribe from Athlon marketing communications at any time using the unsubscribe mechanism included in the communication or by contacting Athlon as described in the “Contact Us” section of this Privacy Policy.
 

Links and References to Other Services

Our Services do not include or provide links to external websites or applications. Our Services may, however, provide a reference to an external website or application. These websites and applications are governed by their own privacy policies or information collection practices, which may be substantially different from ours. We encourage you to review the privacy policies and information collection practices of those linked websites and apps, as those parties’ practices are not subject to this Privacy Policy.

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Location of Information Processing

The Services are controlled and operated by us exclusively from the United States and are intended for use exclusively in the United States. We disclaim and have no liability for use of Services not in compliance with laws outside the United States. In addition, your information may be transferred to, stored, or processed in the United States, whose data protection, privacy, and other laws may not provide the same level of protection as those in your country of residence. For example, government entities in the United States and other countries may have certain rights to access your personally identifiable information. By using our website or the Services, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States and to those third parties with whom we share it as described in this Privacy Policy.

Security

The security of your personal information is important to us, and we employ physical, technical, and administrative security measures to safeguard the information collected by the Services. 

All data we collect is encrypted in transit and at rest, and all personally identifiable information collected by us is transferred using HTTPS and stored by us or a third party provider for us on a server in a secure environment. We limit access to information to personnel and service providers that require access to perform authorized functions, subject to applicable confidentiality, security, contractual, and privacy requirements.

For processing your credit card information, we use a PCI DSS certified provider. 

Please be aware, however, that no information system can be guaranteed to be one hundred percent (100%) secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Services over networks that we do not control, including the Internet and wireless networks. If you have reason to believe that your interaction with us is not secure, please contact us as described in the Section entitled “Contact Us” below.

The safety and security of your information also depends on you. Where we or your Educational Institution or teacher have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 

We have a comprehensive Security Incident Response Plan in place.  Upon the event of a breach, we will provide notice to any potentially affected party within the time required by law.  A public copy of the plan will be provided upon written request (please contact us as described in the Section entitled “Contact Us” below).

Browser Do Not Track

Our website does not support Do Not Track at this time. Do Not Track (DNT) is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits collected across websites when you have not interacted with that service on the page. For all the details, including how to turn on Do Not Track, visit www.donottrack.us.

Changes to Our Privacy Policy

If we update this Privacy Policy, we will notify you by posting the revised Privacy Policy on the Services, and for certain revisions that materially expand the ways in which we use or share the information previously collected from you through the Services, we will either display an alert next to the Privacy Policy, display an alert on the Services, or directly communicate with you in advance of the changes taking effect. Your continued use of the website or the Services after the changes have been made will constitute your acceptance of the changes. Please, therefore, make sure you read any such notice carefully. If you do not wish to continue using the website or Services under the new version of the Policy, please cease using the website and the Services.

Contact Us

Questions regarding this Privacy Policy and issues related to your information or information of a Student User for which you are responsible should be directed to us via any of the following methods:

Email Address: info@letsrallee.com