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Privacy and Security Policy Illinois student data privacy agreement IL-NDPA v1.0a with Exhibit E List of subprocessors used by SpeechWire Tournament Services This Privacy and Security Policy is provided for the benefit of customers and clients of SpeechWire Tournament Services (“SpeechWire”) as well as other consumers and parties who seek information from or about SpeechWire and/or its website(s), particularly speechwire.com (“Website” or “speechwire.com”) (collectively, “SpeechWire Services”). 1. OPENING STATEMENTS 1.1 Definitions. Across its various policies, applications, and Website, SpeechWire strives to use the same definitions for particular terms. By doing so, SpeechWire seeks to make its policies and governing documents consistent and user-friendly. For this reason, SpeechWire provides the definitions for these terms in one location and directs you to our Terms of Use for such definitions. Additionally, any use of “we,” “us,” or “our” refers to SpeechWire as an entity. 1.2 Our Commitment to Privacy. At SpeechWire, we respect the privacy and the confidentiality of our customers’ information, particularly our customers’ PII (also commonly referred to as personally identifiable information) (“PII”). We are committed to keeping confidential the PII you share with us. This Privacy and Security Policy explains how SpeechWire collects, uses, discloses and protects the information we obtain. 1.3 Applicability of Privacy and Security Policy. Our Privacy and Security Policy applies to all individuals and entities from whom or for the benefit of whom we receive PII, whether it be collected through our websites; traditional mailing and/or faxing channels; telephone or electronic communications; from some other medium; and/or from our clients. 1.4 Website Not Directed to Minors. An individual must be aged thirteen (13) or over to create an account or an SMS/email subscription through the Website. As such, the Website is not directed toward children or minors. 2.1 Personally Identifiable Information or PII is any information that would, by itself or in combination, identify you or tend to identify you as a particular individual or entity. This PII may include, but not be limited to, your name, your address, credit card number, bank account information, and/or personal identification number (such as a social security number or driver’s license number). 2.1.1 PII does not include any public information that is readily attainable through federal, state or local public record distribution channels. 2.1.2 PII does not include any information that, by itself or in combination, could not identify you as a particular individual or entity. 2.1.3 PII also does not include raw data that becomes aggregated for statistical purposes and cannot, thereafter, be identified with you as a unique individual or entity. 2.1.4 SpeechWire does consider your Internet Protocol (“IP”) address to be PII and will treat it as such. 2.2 Information Collected 2.2.1 SpeechWire collects information that is considered PII and other information that, by itself, would not be considered personally identifiable information (“Non-PII”). 2.2.2 When you create an account and register for any of our SpeechWire Services (whether through a Website or other portal), we collect information submitted by you including, but not limited to, your username, your full name, company name (if applicable), school name, physical address, email address, telephone number, zip code, and any additional information provided by the account holder that could identify that account holder. We use this information to identify our customers and send notifications related to the use of our SpeechWire Services. We reserve the right to request additional information from you. 2.2.3 SpeechWire may also collect information to one or more of your financial accounts for purposes of processing payments to provide you with SpeechWire Services. This information may likely contain both PII and Non-PII. 2.3 Collecting and Using Personally Identifiable Information 2.3.1 SpeechWire will explain how it intends to use PII either before it collects the information (such as in this Privacy and Security Policy) or contemporaneously with the solicitation of such information. Exceptions may exist where the intended use is obvious to a reasonable person. 2.3.2 We will use the PII collected only for the purposes explained to you. Further, we limit the collection of PII to only that information which is necessary for the purposes explained to you. 2.3.3 SpeechWire may make public the name, contact information, and/or other information of or about Tournament Managers in the normal course of operations to provide coaches and/or other consumers with information about the events that Tournament Managers are running using SpeechWire Services. 2.3.4 We use the PII collected and/or received about you in connection with our Website, Website Services, SpeechWire Services, and their various features. We also use information collected and/or received about you in connection with other users. For example, we may use the information we receive about you (a) as part of our efforts to keep SpeechWire safe and secure; (b) to provide SpeechWire Services; (c) to make suggestions to you and other users on SpeechWire; and (d) to provide support. Additionally, we may use aggregated information derived from PII to improve the SpeechWire Services and any related matters thereto. Granting us this permission, by submitting PII and other data, not only allows us to provide SpeechWire as it exists today, but it also allows us to provide you with innovative features and services we develop in the future that use the PII we receive about you in new ways. 2.3.5 SpeechWire, Tournament Managers using SpeechWire Services to administer their tournaments, Tournament Staff, and league or association administrators may use your PII to communicate with you for the foregoing and other reasons by email, text message, phone call, or other electronic, written or oral communication method, unless you expressly indicate to SpeechWire not to use a particular method of communication. Such indication may result in the removal of information regarding such a method of communication from your Customer account or the removal of your Customer account. 2.3.6 Your submission of PII and other data on this website represents your granting of permission to share that information with Tournament Managers, Tournament Staff, SpeechWire's Strategic Partners, and/or league or association administrators in the normal course of providing SpeechWire Services, such as for the purposes of running tournaments. At the same time, you continue to own, and always own, all of your PII. Your trust is important to us, which is why we do not share PII we receive about you with others unless we have: (a) received your permission; (b) given you notice, such as by telling you about it in this policy; or (c) removed your name and any other PII from it. By submitting your PII and other data using this service, you acknowledge that Tournament Managers, Tournament Staff, or league or association administrators using SpeechWire Services may contact you using those methods. Managers may share with the public, or request that SpeechWire share with the public, data that you provide on this website. That data could include, but is not limited to, the public posting of tournament schedules or results of tournaments, which may contain the information described in Section 2.3.7 below. 2.3.7 SpeechWire users may submit information to SpeechWire about students and other persons for purposes of managing their teams, so that Tournament Managers and Tournament Staff may facilitate operation of tournaments, festivals or other competitions and events. The information submitted may include, but is not limited to, students' or other person's names, competition codes or identifiers, school affiliations, year in school, and information about the selection a student or other person will perform at an event. This information may be shared with other persons or publicly released by the Tournament Manager, Tournament Staff, or league or association administrators. This student information may also be shared publicly by SpeechWire at the request of one of those aforementioned individuals as part of their use of SpeechWire Services. Such releases may include, but are not limited to: the release of results following the event; postings of event schedules/schematics/competition orders/pairings/etc. before, during, or after an event; and lists of participants in an event. This information may be stored indefinitely on media or computers owned by SpeechWire or its Strategic Partners. If you submit information about students or other individuals using the SpeechWire Website or other SpeechWire Services, you affirm that you possess the authorization to include the names of and any associated information about the individuals hereby submitted, and you affirm that you are aware of the ways that SpeechWire uses that information to facilitate events run by tournament managers using SpeechWire Services and that these practices are permissible under applicable laws. 2.3.8 Unless we are required to do so by law, we shall not obtain your consent before collecting PII about you from other parties. Rather, SpeechWire shall presume that you have previously provided such consent to any such third party from whom SpeechWire obtains such information. 2.3.9 In the normal course of its business operations, SpeechWire restricts the use of and access to your PII to SpeechWire’s personnel, its Strategic Partners, Tournament Managers, league or association managers, and Tournament Staff, except where that information has been released as described in this Privacy and Security Policy. 2.3.10 We shall not sell your PII in the normal course of business operations. Should all or any part of SpeechWire’s business operations be sold, this paragraph shall not restrict the transfer of your PII as part of the Website sold to a third party. 2.3.11 SpeechWire will not use information submitted about students to build a profile about them for the purposes of targeting them with advertisements. 2.3.12 We may also use the PII you provide in registering with and using SpeechWire to inform you by electronic mail, phone, text or other communication method of additional products and services about which you might be interested, which may include our periodic e-newsletters and other promotional communications from SpeechWire. 2.4 Disclosing Personal Information 2.4.1 We do not share with others PII we obtain from your use of our SpeechWire Services, except as described in this Privacy and Security Policy and the Terms of Use. 2.4.2 SpeechWire may use PII in the normal course of providing the SpeechWire Services; to operate or improve the Website and/or SpeechWire Services; to outsource certain services to Strategic Partners; to complete a transaction that has been requested; to develop aggregate information; and/or as otherwise disclosed to you. 2.4.3 SpeechWire may provide PII to other persons where (a) we have your consent; (b) the disclosure is necessary to complete a transaction requested; (c) we have obtained information from a third party; (d) we are required or permitted to do so by law; (e) the Website and/or SpeechWire Services are used in a manner that violates the Terms of Use or are used for purposes other than those for which they were specifically intended; or (f) the terms of this Privacy and Security Policy and/or the Terms of Use otherwise permit and/or provide for such disclosure. 2.4.4 Strategic Partners. SpeechWire may employ, engage or retain certain trusted third parties (“Strategic Partners”) to perform functions and/or provide services on its behalf. SpeechWire will share PII with these Strategic Partners only to the extent necessary to perform the functions and/or provide the services for which they have been employed, engaged or retained. 2.4.5 Business Transfers. SpeechWire reserves the right to sell, transfer or otherwise share stored PII in connection with a sale of assets; a merger, acquisition, or reorganization; or filing for bankruptcy. You will have the opportunity to opt out of any such transfer if the planned processing of your information by the purchaser differs materially from that set forth in this Privacy and Security Policy. 2.4.6 Legal Compliance. SpeechWire may disclose any information about you and/or Content created by you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to: (1) comply with an order from a court of competent jurisdiction, regulatory agency, and/or other governmental authority; (2) respond to claims, court orders, or other legal process (including subpoenas); (3) to enforce the terms of this and other SpeechWire agreements as well as to protect the property and rights of SpeechWire, its Strategic Partners or other third parties; (4) to protect, in SpeechWire’s sole discretion, the public or any person from harm; (5) to investigate, prevent, stop, or take other action regarding any action perceived to be fraudulent, illegal, unethical, or legally actionable in SpeechWire’s sole discretion; or, generally, (6) to comply with the law. 2.4.7 Notice. Unless restricted from doing so, SpeechWire will attempt to notify you before it releases any of your PII or Content pursuant to (1) and (2) in Paragraph 2.4.6 only. In such cases, SpeechWire will also provide you with general information on how you may seek to block such a release of information and/or direct you to resources that can provide such general information. The provision of such general information to you is not and should not be construed as providing you with legal advice. Additionally, SpeechWire is under no other obligation to assist you in challenging or opposing a release of your information. 2.5 Non-Personally Identifiable Information. In addition to collecting PII as previously described, SpeechWire also collects other non-PII. Non-PII collected by SpeechWire may be utilized without restriction. Although non-PII can be used in a number of ways, you can be assured that the use of the non-PII cannot identify you as a particular individual. Because non-PII cannot be used to identify you, SpeechWire may in its discretion provide non-PII to other persons or entities. 2.6 Information Obtained from Use of SpeechWire’s Websites 2.6.1 We do not share with others information we obtain from your use of our SpeechWire’s Websites, except as described in this Privacy and Security Policy and the Terms of Use. 2.6.2 Cookies. Cookies can be defined as bits of data stored on your computer that allow websites to identify your browser and session. Most web browsers automatically accept and collect cookies. However, most browsers also allow you to configure them to accept all cookies, reject all cookies, or notify you when a cookie is set. Depending upon your web browser’s security settings, you may have the ability to reject all cookies. If you reject all cookies, you may not be able to use the SpeechWire Services or products that require you to “sign in” and you may not be able to take full advantage of all offerings. The SpeechWire Website may use its own cookies for a number of purposes including, but not limited to: B. Keeping track of preferences specified by our users while using the SpeechWire Website; C. Estimating and reporting our total audience size and traffic; and D. Conducting research to improve the content and services provided on the SpeechWire Website. Our Strategic Partners may use cookies. SpeechWire maintains no control over the use of cookies by our Strategic Partners. For information on how these third parties utilize cookies collected, you should examine their respective privacy policies. 2.6.3 Browser and Session Information. SpeechWire may collect information about your browser and session at the Website and/or using the Website Services. 2.6.4 IP Addresses SpeechWire may maintain a log of Internet Protocol (IP) addresses when any company-owned computers, servers, and/or websites (including, the Website) have been accessed. An IP address by itself does not allow us to collect additional PII about you. IP addresses may be used for various purposes, including to: A. Diagnose and prevent service or technology problems reported by our users or engineers that are associated with the IP addresses controlled by a specific web company or ISP; B. Estimate the total number of users visiting a SpeechWire computer, server and/or website from specific geographical regions. C. Help determine which users have access privileges to certain content, services or resources offered; and, D. Monitor and prevent fraud and abuse. 2.7 Data Retention 2.7.1 SpeechWire shall use commercially reasonable efforts to maintain storage of information subject to the terms of this Privacy and Security Policy and the Terms of Use. 2.7.2 The length of time for which SpeechWire retains PII and other information will vary depending on the nature of the services for which the information has been collected and the nature of the information. 2.7.3 Although this period of retention may extend beyond the end of your relationship with SpeechWire, it will be retained for only so long as necessary for SpeechWire to respond to any issues arising from your relationship with SpeechWire. Data that you provide using SpeechWire services may be retained beyond the end of your relationship with SpeechWire so as to provide services to Tournament Managers, Tournament Staff, or league or association administrators to support their tournaments that may run using SpeechWire Services. Data including, but not limited to, data about participation at events, schedules of events and results of events, which may include data submitted by you, may be retained indefinitely. 2.7.4 When SpeechWire no longer needs or requires your personal information, SpeechWire will destroy, delete, erase or convert information to an anonymous form without notice to you. 2.7.5 Depending on the package of services purchased, SpeechWire may delete information including, but not limited to, stored messages, interviews, videos, audio, other content, and records of your account without notice to you. SpeechWire recommends that you back up on your own computer any critical and important information prior to allowing your SpeechWire Services to terminate or expire. 2.7.6 Should your account be terminated, SpeechWire may immediately and permanently delete all stored messages, interviews, videos, audio, other content, and records of your account without notice to you. 3. CONSENT 3.1 SpeechWire may obtain personal information about you through a variety of sources. For each source or method, the manner of consent may differ. 3.2 In general, SpeechWire operates on an “Opt-out” basis. That is, SpeechWire presumes that by using its SpeechWire Services and/or accessing its Website you have read this Privacy and Security Policy and SpeechWire’s Terms of Use. Moreover, by providing the personal information requested (both personally identifiable and non-personally identifiable), you have consented to its use by SpeechWire for the stated purposes. 3.3 For these reasons, unless and until you expressly inform SpeechWire you do not wish your information to be used, SpeechWire shall presume it has your consent. 3.4 Where SpeechWire obtains information about a consumer from its customers or other third parties, SpeechWire presumes that the consumer has previously provided appropriate consent to the party from whom SpeechWire obtains the information. In any case, the consumer can be assured that this Privacy and Security Policy applies to any information obtained from a third party. 4. ACCESS 4.1 Subject to certain limitations imposed by applicable privacy laws, you may request that SpeechWire provide you with a copy of your personal information and/or information regarding how we have used that personal information. 4.2 Any requests for access to information should be directed to the contact information provided below. 4.3 We will make every effort to respond to your request in a reasonable timeframe. 5. RESERVED. 6. RESERVED. 7. SECURITY 7.1 SpeechWire takes the issue of protecting your anonymity and personal information very seriously. SpeechWire protects the information it obtains about you with appropriate, commercially reasonable safeguards and security measures consistent with standard information practices. These measures include commercially reasonable technical and procedural steps to protect your data from misuse, unauthorized access or disclosure, loss, alteration, or destruction. 7.2 For security purposes, SpeechWire does not disclose all of its security measures. Be assured that SpeechWire does employ commercially reasonable industry standard measures to protect your information. 8. RESERVED. 9. DISCLAIMER AS TO THIRD-PARTY WEBSITES 9.1 Although our company-owned websites may contain links to other third-party websites and/or may be advertised on such third-party websites, SpeechWire is not responsible for the privacy practices or the content of such websites and specifically disclaims any such responsibility. SpeechWire does not monitor the privacy practices or content of these websites. If you have any questions about the privacy practices of a website other than a SpeechWire owned website, you need to contact the Privacy Officer of the website about which you have a question. 10. INCORPORATION OF OTHER APPLICABLE TERMS 10.1 Your use of our Website and SpeechWire Services is subject to this Privacy and Security Policy as well as the Terms of Use, the terms of which are incorporated into this Privacy and Security Policy by reference. You should carefully review the Terms of Use. 11. RESERVED. 12. ADDITIONAL INFORMATION 12.1 When you post content on and/or through the SpeechWire Services, you have the ability to post content which may include personally identifiable information or PII about yourself. You are responsible for the information you (a) post online; (b) post through use of the SpeechWire Services; or, (c) share with another website that you link to from our Website. You do so at your own risk. SpeechWire warns you to be careful in posting information accessible to the public. 12.2 If you post personal information online that is accessible to the public, you may receive unsolicited messages from other parties or other unwanted and possibly harmful contact. SpeechWire warns you to be careful in posting information accessible to the public. 13. CUSTOMER OBLIGATIONS 13.1 By using the SpeechWire Services, you agree to use any information about any other SpeechWire Customer, particularly PII, obtained through SpeechWire Services in a manner consistent with the Terms of Use, this Privacy and Security Policy, and the privacy protections provided for in such policies. 14. REVISIONS TO PRIVACY AND SECURITY POLICY 14.1 SpeechWire reserves the right to revise, amend, or modify this Privacy and Security Policy, our Terms of Use, and other online policies and agreements at any time and in any manner. 14.2 SpeechWire shall provide notice of such changes by posting the revised policies to the applicable SpeechWire owned websites and/or by either (a) providing you a message the next time you login into your account or (b) sending you electronic mail to the email address you provided when creating your account. 14.3 With respect to this Privacy and Security Policy, you should visit our website at speechwire.com from time to time to review the then-current terms. At any time, the current-posted policies govern and shall be binding. For Additional Information or Questions, Contact Us SpeechWire Tournament Services - Copyright 2004-2024 Ben Stewart. All Rights Reserved. Terms of use - Privacy and Security Policy
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