Your privacy is extremely important to us, and we know it is important to you too. After all, The Zone is a place for you to reflect on, and receive support for, your well-being. We believe that The Zone will work best for you if you have the confidence and trust that your private information is being protected and handled appropriately.
We know that privacy policies can be difficult to read. So we want to be clear up front: We will not disclose personal information from your use of The Zone to your school (or anyone else) except in the limited circumstances that we describe below. We do not sell your personal data, and we do not use or share it with others for marketing or advertising purposes.
The main circumstance in which we will disclose limited personally identifiable information to the school is when a user enters the app that the user is feeling “not great” 10 times in a two-week period. In such circumstances, we will only disclose the fact that the named user entered “not great” 10 times in a two-week period, and we will only disclose this information to designated point(s) of contact at the school.
The Zone is not a mental health provider, is not intended to provide mental health treatment or support, and instead is for general well-being and awareness. Also, 10 times of “not great” in two weeks is not a clear or specific number for action, and you may benefit from seeking help and support far sooner. But we have chosen to make the described and limited disclosure to the school in those circumstances to help support safety and well-being by referring you to receive additional support from your school, while also balancing users’ confidentiality and privacy concerns. Further detail is provided in the disclosure and escalation protocols below.
Please read on for additional detail about how we handle and protect your private information.
To operate The Zone, we collect, manage, use and store information that you provide when you sign up for the site and the information that you share on the site. The information we collect is received directly or indirectly from you or your school and generated in the course of your use of The Zone.
The information we collect includes:
Information that you provide when you sign up for The Zone, and that you share when using the platform.
Your name, email address, phone number, and school sports team(s).
Your interaction with The Zone app, including data, entered and responses to question prompts, pages visited or viewed, and the amount of time spent on the app.
We may use your email address to communicate with you or to connect you with school personnel. Your email address is not used for any other purpose and is not shared with outside parties except your school for the limited purpose specified. While The Zone may use a link to your email address to help you establish a connection with your school points of contact, The Zone does not review, access or store any emails that you draft or send through that email contact.
Information about your mobile device ID to identify your account and deliver notifications.
HOW WE USE INFORMATION
The Zone may use the information we collect for purposes including:
To communicate with you, including providing you with information, alerts, and suggestions directly related to your use of the platform; to verify your sign-on credentials; to assist you in beginning an email to certain designated people at your school; and, in limited circumstances specified here, to communicate with you and the designated point(s) of contact at your school if you indicate you are feeling “not great” a specified number of times, in order to assist you in seeking or obtaining additional support.
To deliver services to you, including to create your account and enable you to log into your account and use the platform; to manage your account and provide you with customer support; to personalize your experience with The Zone by enabling guided self-reflections and suggesting particular on-platform content and services based on the data you input and using our algorithms and machine learning programs; and to connect you with indirect or direct points of contact at the school who may be able to provide you with assistance and support.
To comply with the law, namely, if we are obligated to respond to law enforcement requests or otherwise required by law, court order or government regulation.
Other uses with consent, if you are informed and agree to another purpose.
IMPORTANT INFORMATION ON PRIVACY, DISCLOSURE AND ESCALATION:
To any person when you authorize such disclosure;
To information technology service providers subject to written confidentiality agreements, in order to assist us in maintaining and operating our platform and in ensuring the confidentiality and security of user data;
To government or regulatory agencies, and to comply with a legal summons, court order, subpoena or similar legal process, audit or investigation; and
By using The Zone you agree to provide contact information that we can share with your school under the limited circumstances below. You also acknowledge and agree to The Zone’s disclosure and escalation protocols, as follows:
These protocols are in no way intended to suggest that you should wait until a certain point to reach out for direct contact with your school or a qualified mental health professional; The Zone encourages you to do so as often and as early as may be helpful to you. The Zone also has no responsibility for the actions, inactions, communications, or interactions between you and your school or mental health providers. The Zone is not and should not be considered medical advice.
The Zone may use anonymized and aggregated information for various purposes. As stated above, we provide anonymized updates to your school. For example, we may notify your school that X number of individuals at the school or on an identified sports team are using The Zone on a daily basis, or that Y percent of students at the school or on an identified sports team have indicated they are feeling “great” or “not great” for particular reasons (i.e., academic, physical, etc.). We may also use or share anonymized and aggregated data to better design and operate our platform; for research, trend analysis, publication in school reports, media platforms, academic journals, or other forms of public dissemination; or for other academic or commercial purposes determined by The Zone. As stated above, we use a minimum aggregation threshold of 10 individuals when sharing anonymized and aggregated data.
The Zone does not sell any personally identifiable information of our users, and we do not use or share personal user data for marketing or advertising purposes.
The Zone stores your personal data only for as long as necessary to provide products and services to you and/or your school, including those described above, and for legal protection or as required by applicable laws and regulations.
HOW WE PROTECT PERSONAL INFORMATION
The Zone applies commercially reasonable industry standards and practices to prevent any unauthorized access, use and disclosure. We also comply with applicable federal and state laws and regulations regarding data privacy. While using any internet-based service carries inherent security risks that cannot be 100% prevented, our systems, infrastructure, encryption technology, operation, and processes are designed and maintained with your privacy and security in mind.
To help safeguard your personal information, we:
Use industry-standard encryption technologies, including when transferring and receiving consumer data exchanged with our site;
Use firewall barriers and digital certifications;
Restrict access to only to those personnel for whom the information is necessary as part of their job responsibilities;
Enter into written confidentiality/non-disclosure agreements with third-party service providers;
Maintain physical, electronic, and procedural safeguards that comply with relevant laws and regulations;
Educate personnel about information security policies and procedures and their role in safeguarding information and systems;
Educate personnel about the importance of confidentiality and user privacy, and their roles in protecting user data;
The Zone does not knowingly collect or solicit any information from anyone under the age of 13, or knowingly allow such persons to become our users. If you are aware that we have collected personal information from a user under the age of 13, please contact us at email@example.com and we will delete that information.
The Zone may employ third parties to assist us in maintaining, securing, operating, and further developing our platform, or to provide audit, legal, operational, and other services to assist our operations. For example, we may work with third parties regarding customer service, technical maintenance and updates, communications, database management, security, analytics, reporting, and improvements to The Zone. Those entities or individuals would only have access to the information and systems necessary to perform their tasks and would be subject to The Zone’s confidentiality requirements.
QUESTIONS AND UPDATES
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
If you are a California resident under the age of 18 and a registered user of The Zone, California Business and Professionals Code Section 22581 permits you to request and obtain the removal of content or information you have publicly posted on The Zone (this is referred to as the “Eraser Law”). Note The Zone does not have users below age of 13 and does not typically allow any users to publicly post information. However, if you feel you publicly posted information on The Zone and are between the ages of 13 and 17, please contact us at firstname.lastname@example.org to request the removal of data or content that you have posted, where such removal is not otherwise prohibited.
Under the California “Right to Know,” you may request access to the specific pieces of personal data we have collected about you in the last 12 months. You also may request additional details about our information practices (including categories of personal data collected about you, sources of the collection, categories of personal data shared for a business or commercial purpose, and categories of third parties with whom we may share your personal data). You may make these requests by contacting us at email@example.com. You also may designate an agent to make a request on your behalf (the “California Designated Agent”); that Designated Agent must have access to your account so we may verify the request.
Non-Discrimination: The Zone will never discriminate against you, including by denying or providing a different level of service should you choose to exercise your rights under the CCPA.
Reasonable time: For any requests under CCPA, please allow for a reasonable time for a response.
PRIVACY IN INTERNATIONAL USE AND THE GDPR
The Zone may use your personal information:
When necessary to perform our obligations under any contract with you, to manage your account, or to address inquiries about your use of The Zone.
When we or a third party have a legitimate interest to use personal information in such a way to ensure that we operate The Zone most effectively and efficiently. This includes our legitimate interest in using your personal information for product development and internal analytics purposes, and to improve the safety, security, and performance of The Zone, provided your rights and interests do not override these interests.
When necessary to comply with applicable law or any other legal obligations imposed upon us.
When you consent to the use of your personal information.
Right of access: You may be entitled to ask us for a copy of any personal information which we hold, in the form of a “Subject Access Request.”
Right to rectification: If the personal information we hold about you is inaccurate, you may request that we check, and, where appropriate, we will correct any inaccuracies.
Right to erasure: In certain circumstances, you may be entitled to ask us to erase your personal information.
Right to data portability: In certain circumstances, you may wish to move, copy, or transfer the electronic personal Information that we hold about you to another organization.
Right to object: The Zone does not use your personal information for marketing but we note that, under the GDPR, you may object if your personal information were being used for direct marketing. You also may object to the continued use of your personal information in any circumstances where we rely upon consent as the legal basis for processing it. Where we rely upon legitimate interests as the legal basis for processing your personal information, you may object to us continuing to process your personal information, but you must give us specific reasons for objecting. We will consider the reasons you provide, but if we consider that there are compelling legitimate grounds for us to continue to process your personal information, we may continue to do so. In that event, we will let you know the reasons for our decision.
To exercise these rights, or for any questions about this policy or your personal information, you can contact us at: firstname.lastname@example.org; please provide enough specificity and allow us a reasonable time to respond to your request.
We would like to work with you to resolve any concerns you may have about the use of your personal information. We also note that, under GDPR, you have the right to lodge a complaint with the supervisory authority in your country of residence if you have any concerns about our use of your personal information.
Last updated 9/28/2022