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Privacy Policy & Data Collection.
1. Introduction
WMC Analytics Inc. ("DataCoach," "we," "us," or "our") operates the RLDataCoach.com website and related services (collectively, the "Service"). We are committed to protecting the privacy and security of student information in accordance with the Family Educational Rights and Privacy Act ("FERPA"), the Children's Online Privacy Protection Act ("COPPA"), and applicable state privacy laws.
This Privacy Policy explains how we collect, use, disclose, and protect information when educational institutions and their students use our video game coaching platform.
Contact Information:
WMC Analytics Inc.
Attention: Joshua Robinson, CEO
2967 Dundas St. W. #521D
Toronto, ON M6P 1Z2
Email: josh@rldatacoach.com
2. Our Service
DataCoach provides personalized video game coaching services to help high school students improve their gaming skills. We operate as an Epic Games API partner, allowing students to access our platform using their existing Epic Games login credentials.
3. Information We Collect
3.1 Information Collected Directly
When students use our Service through their school, we collect:
Email addresses provided by the school or student
Epic Games usernames to provide coaching services
Gaming performance data retrieved through the Epic Games API to deliver personalized coaching
3.2 Information We Do NOT Collect
We do not collect:
Student names or personally identifiable information beyond email addresses
Student ID numbers
Grade levels or ages
Academic performance data
Photographs, videos, or audio recordings
IP addresses or device identifiers for tracking purposes
Social Security numbers or other government identifiers
3.3 Authentication
Students authenticate to our Service using their Epic Games login credentials. We do not store or have access to these login credentials. Authentication is handled directly by Epic Games through their secure API.
4. How We Use Information
We use the information we collect solely to:
Provide personalized video game coaching services
Generate performance analytics and coaching recommendations
Improve our coaching algorithms and Service functionality using anonymized data
Communicate with schools regarding service delivery
Comply with legal obligations
We do NOT:
Sell, rent, or license student information to third parties
Use student information for advertising or marketing purposes
Share student information with third parties except as described in this policy
Build student profiles for non-educational purposes
5. Information Sharing and Disclosure
5.1 No Third-Party Sharing
We do not share student information with third parties for their own purposes. All data processing occurs within our secure systems hosted on Amazon Web Services (AWS).
5.2 Service Providers
We use AWS as our hosting infrastructure provider. AWS provides only data storage and computing services and does not have access to or use student data for any purpose other than providing hosting services under our direction.
5.3 School Access
Schools that contract with us retain ownership of all student data. We provide schools with access to student data and analytics as part of our Service.
5.4 Legal Requirements
We may disclose information if required by law, court order, or legal process, or to protect the rights, property, or safety of DataCoach, our users, or others.
6. FERPA Compliance
6.1 School Official Status
When providing services to educational institutions covered by FERPA, DataCoach operates as a "school official" with a legitimate educational interest in accessing student education records. We:
Perform services that the school would otherwise use its own employees to perform
Are under the direct control of the school with respect to the use and maintenance of education records
Use personally identifiable information from education records only for authorized purposes
Do not re-disclose personally identifiable information without school authorization
6.2 Direct Control by Schools
Schools maintain direct control over student data through:
Contractual agreements specifying permitted data uses
The ability to audit our data practices
The right to request data access, correction, or deletion at any time
Approval requirements for any changes to our data handling practices
6.3 Parent and Eligible Student Rights
Under FERPA, parents and eligible students have the right to:
Inspect and review education records maintained by us on behalf of the school
Request correction of inaccurate or misleading information
Consent to disclosures of personally identifiable information (except as permitted by FERPA)
To exercise these rights, parents and eligible students should contact their school, which will coordinate with us as necessary.
7. COPPA Compliance
7.1 Parental Consent Through Schools
Our Service is provided exclusively to schools for educational purposes. Under COPPA, schools may consent to the collection of personal information from students under 13 on behalf of parents when the collection is for the use and benefit of the school and for no other commercial purpose.
We rely on schools to obtain any necessary parental consent before students under 13 use our Service. We do not knowingly collect personal information directly from children under 13 without school authorization.
7.2 Information Collection from Children
For students under 13 using our Service through their school:
We collect only the information necessary to provide coaching services (email address and Epic Games username)
We do not condition participation on disclosure of more information than is reasonably necessary
We do not use student information for behavioral advertising or building profiles for non-educational purposes
We implement reasonable security measures to protect children's information
7.3 Parental Rights
Parents have the right to:
Review their child's personal information collected through the Service
Request deletion of their child's personal information
Refuse to permit further collection or use of their child's information
Parents should contact their child's school to exercise these rights, or may contact us directly at josh@rldatacoach.com.
8. Data Security
8.1 Security Measures
We implement comprehensive security measures to protect student information, including:
End-to-end encryption of data in transit and at rest
Two-factor authentication for administrative access
Access controls limiting employee access to student data on a need-to-know basis
Regular security assessments and updates to our security protocols
Secure cloud hosting with AWS, which maintains industry-standard security certifications
Employee training on data privacy and security best practices
8.2 Data Breach Notification
In the event of a data breach involving student information, we will:
Notify affected schools within 72 hours of discovery
Cooperate with schools in notifying parents and students as required by law
Take immediate steps to mitigate the breach and prevent future incidents
Document the breach and our response in accordance with applicable regulations
9. Data Retention and Deletion
9.1 Retention Period
We retain student information only as long as necessary to provide services under our contract with the school. When a school's contract with us ends, we will:
Anonymize all student data within 30 days, or
Delete all student data at the school's request
9.2 Anonymization Process
When we anonymize data, we remove all personally identifiable information, including email addresses and Epic Games usernames. Anonymized data cannot be linked back to individual students and may be retained for product improvement purposes.
9.3 Deletion Requests
Schools, parents, or eligible students may request deletion of student data at any time by contacting us at josh@rldatacoach.com. We will delete the requested data within 30 days unless retention is required by law.
10. Third-Party Links and Services
10.1 Epic Games Integration
Our Service integrates with Epic Games' API for authentication and to retrieve gaming performance data. Students authenticate using their Epic Games credentials, which are managed directly by Epic Games. Epic Games' use of student information is governed by their own privacy policy, available at their website.
10.2 No Other Third-Party Services
We do not integrate with or share data with any other third-party services, analytics platforms, or advertising networks.
11. Cookies and Tracking Technologies
We do not use cookies, web beacons, or other tracking technologies within our application once students are authenticated. Students authenticate through Epic Games, which may use its own cookies in accordance with its privacy policy.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will:
Notify schools of material changes at least 30 days before they take effect
Post the updated policy on our website with a new "Last Updated" date
Obtain school consent before making material changes that affect the use of student data
Continued use of the Service after changes take effect constitutes acceptance of the updated Privacy Policy.
13. State-Specific Privacy Rights
Depending on your location, you may have additional privacy rights under state laws such as:
California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)
Virginia Consumer Data Protection Act (VCDPA)
Colorado Privacy Act (CPA)
Other state student data privacy laws
We comply with applicable state privacy laws and will honor requests under these laws. Please contact us at josh@rldatacoach.com for more information about your state-specific rights.
14. International Users
Our Service is hosted in the United States and intended for use by schools and students in the United States. If you access our Service from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located.
15. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
By Email:
josh@rldatacoach.com
By Mail:
WMC Analytics Inc.
Attention: Privacy Officer
2967 Dundas St. W. #521D
Toronto, ON M6P 1Z2
For Schools:
Schools may contact us to exercise their rights under FERPA, request data access or deletion, or discuss data security measures.
For Parents and Students:
Parents and eligible students should first contact their school to exercise privacy rights. You may also contact us directly using the information above.
16. Definitions
Education Records: Records directly related to a student maintained by an educational institution or party acting for the institution.
Personally Identifiable Information (PII): Information that, alone or in combination, can be used to identify a specific individual, including names, email addresses, and online identifiers.
School Official: A contractor, consultant, volunteer, or other party to whom an educational institution has outsourced institutional services or functions, and who has a legitimate educational interest in education records.
Eligible Student: A student who has reached 18 years of age or is attending a postsecondary institution.
Acknowledgment
By using DataCoach services, schools acknowledge that they have read, understood, and agree to the terms of this Privacy Policy and confirm they have obtained any necessary parental consent for students under 13 to use the Service in accordance with COPPA.