IN the GAME with DOC | Live Sports Broadcasting Platform

1. Introduction

Don O'Connor Media ("we," "us," "our") operates the IN THE GAME platform (the "Platform"). We are committed to protecting your privacy and handling your personal information with transparency and care. This Privacy Policy explains how we collect, use, store, protect, and disclose information when you use the Platform.

This policy applies to all users of the Platform, including athletes, coaches, recruiters, parents/guardians, guests, and viewers. We comply with the Children's Online Privacy Protection Act (COPPA), applicable Tennessee state laws, and all other relevant privacy regulations.

2. Information We Collect

2.1 Information You Provide

Account Information: Username, email address, password (encrypted), first and last name
Profile Information: School name, graduation year, position/sport, profile photo, athletic stats, and biographical information you choose to share
Media Content: Videos, images, and other media you upload, including athletic drills, highlights, and performances
Age Verification: Date of birth (used solely for age verification and not retained for other purposes)
Parental Information: Parent/guardian email and name (for COPPA compliance purposes only)

2.2 Information Collected Automatically

Usage Data: Pages visited, features used, time spent on Platform
Device Information: Browser type, device type, operating system, IP address (anonymized)
Streaming Data: Connection quality metrics (bitrate, latency) for service optimization
Cookies: Essential cookies for authentication and platform functionality

2.3 What We DO NOT Collect

🚫 Driver's license numbers or government-issued IDs
🚫 Full credit or debit card numbers (Stripe handles payments — we only store a payment ID reference)
🚫 Location tracking data (GPS or precise location)
🚫 Private messages or chat content (beyond guest streaming sessions)
🚫 Medical or health information
🚫 Social Security numbers

3. How We Use Your Information

We use the information we collect for the following purposes:

✅ To create and manage your account
✅ To provide, maintain, and improve the Platform's features and functionality
✅ To verify your age and comply with COPPA requirements
✅ To process parental consent for users under 13
✅ To broadcast and share your athletic content as you direct
✅ To communicate with you about platform updates, support requests, and policy changes
✅ To detect, prevent, and address technical issues, fraud, and abuse
✅ To moderate content and enforce our community guidelines
✅ To comply with legal obligations and regulatory requirements

We DO NOT sell your personal information to third parties. We DO NOT use your data for behavioral advertising or marketing profiling.

4. COPPA Compliance — Children Under 13

🔒 Our Commitment to Children's Privacy

In compliance with the Children's Online Privacy Protection Act (COPPA), we have implemented the following protections for users under 13:

Age Gate: We require a date of birth at registration. If a user indicates they are under 13, their signup is halted immediately and NO personal data is stored.
Verifiable Parental Consent: Before any data can be collected from a user under 13, we require verifiable parental consent through one of these FTC-approved methods:
- 🎥 Video chat verification with our staff
- 📝 Signed parental consent form returned via email or mail
- 💳 Credit card micro-transaction ($0.50, fully refunded)
Zero Data Before Consent: We do not collect, store, or process any personal information from under-13 users until verifiable parental consent has been obtained.
Minimal Data Collection: We only collect athletic-related information and account essentials — nothing more than necessary.
Parental Control: Parents can review, modify, or delete their child's data and revoke consent at any time.

Data We May Collect After Consent: Only athletic-related information (username, stats, media uploads, school name) and basic account information (email, parent contact). We never collect location data, private messages, or sensitive personal information from children.

5. Parental Rights & Data Control

Parents and legal guardians have the following rights regarding their child's information:

🔍 Right to Review

Request to review all personal information we have collected about your child. We will respond within 30 days.

✋ Right to Revoke

Revoke your consent at any time via the consent link sent to your email. Data collection will stop immediately.

🗑️ Right to Delete

Request deletion of your child's data by contacting doc@donoconnor.com. We will delete all data within a reasonable timeframe.

🚫 Right to Restrict

Restrict further collection or use of your child's information. Your child's account will be limited accordingly.

To exercise any of these rights, email us at doc@donoconnor.com with your name, your child's username, and the action you request. We may need to verify your identity before processing your request.

6. How Consent Verification Works

When a parent chooses to provide consent, we use one of the following methods, each designed to minimize data retention while satisfying COPPA requirements:

🎥 Video Chat Verification

A LiveKit video room is created where the parent speaks with our staff. The video call is NOT recorded — only a log entry recording that the verification occurred, the method used (video_chat), the date, and the time. No video or audio footage is stored.

📝 Signed Consent Form

The parent downloads a consent form PDF, signs it, and returns it via email. Our staff reviews the form and logs the verification event. The signed form is retained securely for compliance purposes. Driver's license numbers or other government ID numbers are NEVER extracted or stored — the form only verifies parent identity through the email address and signature.

💳 Credit Card Authorization

A $0.50 micro-transaction is processed via Stripe to verify the parent is a real adult with a valid payment method. The $0.50 is immediately refunded. We store ONLY the Stripe payment transaction ID for audit purposes — we NEVER store the full credit card number, CVV, or expiration date.

7. Audit Trail & Data Retention

In compliance with Tennessee law, we maintain an immutable audit log of all age verification and parental consent events. Each log entry records:

The type of event (age gate denial, consent given, consent revoked, etc.)
The verification method used (video chat, signed form, or credit card)
The date and timestamp of the event
A hashed identifier (not the actual name or email — encrypted, irreversible)
The staff member who handled the verification (if applicable)

NOT stored in audit logs: Driver's license numbers, full credit card numbers, addresses, or any personally identifiable information beyond a hashed reference.

Account data is retained for as long as the account is active. Upon account deletion or consent revocation, we delete all personally identifiable information within 30 days, except where retention is required by law (e.g., audit logs, which exist without PII).

8. Data Sharing & Third Parties

We share information only in the following limited circumstances:

Service Providers: We use trusted third-party services (Stripe for payments, LiveKit for streaming, Cloudflare for CDN) that process data on our behalf. These providers are contractually bound to protect your data and use it only for the services we request.
Legal Compliance: We may disclose information if required by law, court order, or government request, or to protect our rights, property, or safety.
Public Content: Information you choose to share publicly on your profile or in media uploads is visible to other users as directed by your privacy settings.

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

9. Data Security

We implement industry-standard security measures to protect your information:

🔐 All data transmitted over TLS/SSL encryption
🔐 Passwords hashed using Argon2 or bcrypt (never stored in plaintext)
🔐 Token-based authentication with JWT, short expiration times
🔐 Regular security audits and dependency updates
🔐 Access controls — only authorized personnel can access user data
🔐 Cloudflare Turnstile anti-bot protection on registration forms

While we take every reasonable precaution, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security but will notify you of any data breach as required by applicable law.

10. Cookies & Tracking

We use only essential cookies necessary for the Platform to function:

Authentication cookies (session management, login state)
Security cookies (CSRF protection, anti-abuse measures)
Functional cookies (remembering preferences)

We do NOT use tracking cookies, advertising cookies, or third-party analytics cookies that profile your behavior across websites. For more details, see our Cookie Policy.

11. Your Rights (All Users)

Depending on your jurisdiction, you may have the following rights regarding your personal information:

Access: Request a copy of the personal information we hold about you
Correction: Request correction of inaccurate or incomplete information
Deletion: Request deletion of your personal information (subject to legal retention requirements)
Portability: Request a machine-readable copy of your data
Objection: Object to certain processing activities

To exercise any of these rights, contact us at doc@donoconnor.com. We will respond within 30 days.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or through a notice on the Platform. The "Last Updated" date at the top of this page reflects the most recent changes. We encourage you to review this policy periodically.

13. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy, please contact us:

Email: doc@donoconnor.com

Platform: Contact Form

Privacy Concerns: privacy@donoconnor.com

Don O'Connor Media
Nashville, Tennessee
United States

For COPPA-specific inquiries, please include "COPPA" in the subject line of your email so we can prioritize your request.

14. Tennessee Law Compliance

In compliance with Tennessee state law regarding data privacy and parental consent verification:

We do not retain copies of driver's licenses or government-issued identification
We do not retain full credit card numbers — only payment transaction IDs for audit purposes
We maintain a compliance log of verification events (method, date, time) without storing PII
Parents may request a copy of the compliance log entries related to their child
We comply with all applicable Tennessee data breach notification requirements