Privacy Policy

This Privacy Policy explains how CTSO Manager, LLC ("CTSOManager," "we," "us," or "our") collects, uses, discloses, and protects information through CTSOManager.com and any related applications and services (the "Service"). It should be read together with our Terms of Service & Acceptable Use Policy, which governs use of the Service more broadly.

1. Information we collect

The Service collects information in a few different ways, depending on your role:

• Account information. Name, email address, and (for accounts not using Google Sign-In) a password. Role assignments (student, teacher, judge, volunteer, alumni, administrator, etc.) and the chapter, region, state, or national scope they apply to.
• Student roster data. Entered by a teacher, chapter advisor, or through an approved account request: name, membership number, grade level, and other roster fields a chapter chooses to record, such as contact and demographic information provided for chapter management purposes.
• Accommodation information. Where a student has a testing accommodation on file (for example, extended time or read-aloud support), the accommodation type and any supporting notes a teacher or administrator chooses to record, used only to apply that accommodation during testing.
• Competition and testing data. Event registrations, team assignments, rubric scores, judge feedback, test answers and results, and placements.
• Conference logistics data. Hotel room assignments, schedule/job sign-ups, and similar conference-specific records.
• Billing information. Invoices, fee schedules, and payment/refund records. We do not directly collect or store full payment card or bank account numbers - see Section 6 of the Terms of Service.
• Usage and log data. Standard web server logs (such as IP address, browser type, and pages visited) generated automatically as part of operating the Service.
• Cookies. See Section 5 below and our Cookie Notice.

2. How we use information

We use the information above only to operate, maintain, secure, and improve the Service for its intended purpose, including to:

• Create and manage accounts, roles, and permissions.
• Run conference registration, scheduling, judging, testing, and results.
• Generate invoices and record payments and refunds.
• Send account-related and Service-related communications (such as newsletters a teacher or event manager sends to their own chapter or conference, or a notification that a survey or set of results has been posted).
• Detect, investigate, and prevent misuse of the Service, consistent with our Acceptable Use Policy.
• Diagnose technical problems and improve the Service's reliability and features.

We do not use student data, and do not use account data generally, for targeted advertising, and we do not sell personal information.

3. FERPA and student data

For student data, CTSOManager acts as a service provider performing functions on behalf of participating schools and chapters - comparable to the role a school official would otherwise perform - consistent with the "school official" exception under the Family Educational Rights and Privacy Act (FERPA), 34 CFR § 99.31(a)(1). As between CTSOManager and a school, chapter, or organization, student education records and related data remain the property of that school, chapter, or organization; we do not claim ownership of it, and we use it only for the educational and competitive-event purposes described above.

A school, chapter, or organization administrator may request access to, correction of, or deletion of student data it controls by contacting us via our Contact page, subject to any records we are required to retain for legal, accounting, or dispute-resolution purposes.

4. Children's privacy (COPPA)

The Service is not knowingly directed at, or intended for use by, children under 13, and we do not knowingly collect personal information from children under 13 without the consent required by the Children's Online Privacy Protection Act (COPPA). BPA membership - the CTSO the Service currently supports - is generally high-school and post-secondary age. If we later learn that a child under 13 has provided personal information without the required consent, we will take reasonable steps to delete that information; a parent or school administrator who believes this has happened can contact us via our Contact page.

5. Cookies

The Service uses a small number of cookies that are strictly necessary for it to function - primarily to keep you signed in and to protect forms from cross-site request forgery - plus one cookie that remembers whether you've dismissed the cookie notice banner. We do not currently use advertising or cross-site tracking cookies. Full detail on exactly what's used and how to control it is in our Cookie Notice.

6. How we share information

We do not sell personal information. We disclose it only:

• To the school, chapter, teacher, judge, or other user roles that need it to perform their function within the Service, consistent with each role's permissions;
• To service providers who process data on our behalf under confidentiality obligations - for example, our cloud hosting provider, our object-storage provider for uploaded files, and (once online payment collection is enabled) a payment processor;
• As required by law, subpoena, or court order; or
• With the consent of the applicable school, chapter, or parent/guardian where required.

7. Data retention

We retain account and student data for as long as the associated account or chapter remains active on the Service, plus a reasonable period afterward for legal, accounting, and dispute-resolution purposes, unless a school, chapter, or organization administrator requests earlier deletion of data it controls (subject to records we're required to retain).

8. Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect information against unauthorized access, use, or disclosure, including encrypted connections (HTTPS) to the Service and routine backups. No method of storage or transmission is completely secure; if we confirm a security incident affecting your information, we will notify affected schools, chapters, or organizations without unreasonable delay and in accordance with applicable law.

9. Your choices and rights

Depending on your role and location, you may have rights to access, correct, or request deletion of your personal information. For a student, these requests are generally made through the student's school, chapter advisor, or organization administrator, consistent with FERPA and the school's own policies; anyone can also reach us directly via our Contact page.

Residents of California, Colorado, Connecticut, Virginia, Utah, and a growing number of other states have additional rights under their state's consumer privacy law (such as the right to know what personal information is collected, and to request its correction or deletion). We honor these rights for personal information covered by those laws - contact us at the email above to make a request.

10. Where we operate

The Service is operated in the United States and is intended for use by organizations and individuals in the United States.

11. Changes to this Policy

We may revise this Privacy Policy from time to time. If we make a material change, we will provide reasonable notice (for example, by posting a notice in-app or emailing chapter/organization administrators) before the change takes effect.

12. Contact us

Questions about this Privacy Policy, or requests regarding your information, can be directed to us via our Contact page.