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Privacy Policy

Version 1.1 · Effective June 2026 · Epicentra LLC · Governing Law: Commonwealth of Massachusetts

Attorney Review Note: This document has been prepared for pre-deployment review and is subject to revision by qualified legal counsel before execution with any Institution. CCPA, GDPR, SOPIPA, and FERPA provisions should be reviewed by counsel familiar with applicable data protection law and Massachusetts commercial law.

This Privacy Policy describes how Epicentra LLC ("Epicentra," "we," "us," or "our") collects, uses, stores, and protects information in connection with: (a) your use of the Rah-AI: Vantage website at www.epicentrallc.com and associated landing pages (the "Website"), and (b) your use of the Rah-AI: Vantage software platform (the "Platform"). By using the Website or the Platform, you agree to the practices described in this Policy.

This Policy is organized in two sections. Part A covers information collected through the Website (applicable to all visitors). Part B covers information collected through the Platform (applicable to subscribing Institutions and their Authorized Users). Certain sections in Part C apply to both.

Table of Contents
  1. Who We Are
  2. Part A — Website Privacy (All Visitors)
  3. Part B — Platform Privacy (Institutions and Authorized Users)
  4. Part C — Provisions Applicable to All
  5. Student-Athlete Privacy
  6. Third-Party Sub-Processors
  7. Data Retention
  8. California Privacy Rights (CCPA)
  9. International Users (GDPR)
  10. Children's Privacy
  11. Your Rights and Choices
  12. Security
  13. Changes to This Policy
  14. Contact

1. Who We Are

Epicentra LLC is a Massachusetts limited liability company that operates Rah-AI: Vantage, an AI-native statistical profile evaluation platform for college athletic departments and sports organizations. Epicentra is the data controller for information collected through the Website and the data processor for User Data processed through the Platform on behalf of subscribing Institutions.

Our primary contact for all privacy matters is support@epicentra-llc.com.

2. Part A — Website Privacy

Website Visitors

2.1 Information We Collect from Website Visitors

When you visit the Website or submit a demo or contact request, we may collect:

We do not collect payment information, government IDs, or any sensitive personal data through the Website.

2.2 How We Use Website Visitor Information

Information submitted through the Website is used solely to:

We do not sell, rent, or share Website visitor information with third parties for marketing or advertising purposes.

2.3 Cookies and Tracking

The Website does not use advertising cookies, retargeting pixels, or third-party behavioral tracking. We do not run advertising or retargeting campaigns that track Website visitors across other websites. Basic session and performance data may be collected by our hosting infrastructure (Vercel) solely for availability and performance purposes. We do not use Google Analytics or similar third-party analytics services on the Website.

2.4 Website Data Storage

Demo and contact request submissions are stored securely within Epicentra's administrative systems. We retain this data for up to twenty-four (24) months from the date of submission, or until you request deletion, whichever comes first.

3. Part B — Platform Privacy

Platform Users

3.1 Account Information

When an Institution is granted access to the Platform, we collect for each Authorized User: username, program name, user role, and login timestamps. We do not collect billing or payment information directly through the Platform — institutional subscription agreements are managed separately.

3.2 User-Generated Data

We collect data that Authorized Users actively create within the Platform, including:

3.3 Player Profile Data

The Platform indexes publicly available statistical data about collegiate athletes, including game statistics, school and conference affiliation, eligibility year, and position. This data is sourced exclusively from publicly available sources. We do not collect private medical, financial, academic, or personal communications data about student-athletes. See Section 5 for our full student-athlete privacy commitment.

3.4 Usage and Technical Data

We automatically collect the following data for platform security, debugging, and performance monitoring:

This data is used solely for operating and improving the Platform and is never shared with third parties for marketing purposes.

3.5 Consent and Acceptance Records

We record each Authorized User's acceptance of the Platform Terms of Service, including: username, Terms version accepted, timestamp, IP address, and browser user agent. These records constitute an immutable legal audit trail and are retained for the duration of the Institution's subscription plus five (5) years.

3.6 Output Audit Logs

The Platform logs all Output Document generation events, including username, institution, profile evaluated, timestamp, and output parameters. These logs are retained for not less than three (3) years and may be used to investigate misuse of Platform outputs or breaches of the Terms of Service.

3.7 How We Use Platform Data

Platform data is used to:

We do not sell, rent, or share Platform data with third parties for marketing or advertising purposes. We do not use Player Profile Data to train AI models for sale to third parties.

3.8 Data Isolation

Each Institution's User Data is strictly isolated. Rosters, notes, watchlists, and budget preferences are accessible only to authenticated Authorized Users within that Institution's account. No cross-Institution data access is permitted at any level of the system. Database-level row isolation by Institution is enforced in all production environments.

4. Part C — Provisions Applicable to All

All Users

The provisions in Sections 5 through 14 apply to both Website visitors and Platform users unless otherwise specified.

5. Student-Athlete Privacy

Epicentra is committed to the responsible use of collegiate athlete data. Our commitments are:

5.1 FERPA

The Platform does not receive student education records from subscribing Institutions and is not a "school official" as defined under the Family Educational Rights and Privacy Act (FERPA). Institutions must not transmit, upload, or otherwise provide FERPA-protected student records to the Platform. Epicentra is not responsible for FERPA compliance obligations arising from an Institution's unauthorized transmission of student education records.

5.2 SOPIPA and State Student Data Laws

The Platform is designed to operate using only publicly available data and does not collect student personal information as defined under the California Student Online Personal Information Protection Act (SOPIPA) or New York Education Law § 2-d. Institutions that require a Data Processing Addendum (DPA) for applicable state law compliance may request one at support@epicentra-llc.com.

6. Third-Party Sub-Processors

The Platform uses the following third-party infrastructure providers. Each is bound by its own privacy and security policies. All data is stored in U.S.-based infrastructure.

Sub-Processor Purpose Data Location
Railway (railway.app) Cloud hosting and PostgreSQL database infrastructure United States
Vercel (vercel.com) Frontend hosting and content delivery United States
Google Workspace Internal communications and administrative data storage United States

We do not integrate with any NIL marketplace, NCAA clearinghouse, CSC reporting platform, or athlete data broker. Epicentra will update this sub-processor list and notify affected Institutions of any material changes at least thirty (30) days in advance.

7. Data Retention

Data Type Retention Period
Website visitor and demo request data 24 months from submission, or until deletion request
Platform User Data (active subscription) Duration of authorized access
Platform User Data (post-termination) 90 days in secure backup, then permanently deleted
Consent and ToS acceptance records Subscription term plus 5 years
Output audit logs Minimum 3 years
Aggregated, anonymized usage analytics Indefinitely (no personal data)

You may request deletion of your data at any time by contacting support@epicentra-llc.com. We will respond within thirty (30) days. Note that certain data may be retained longer where required by applicable law or for legitimate legal or audit purposes.

8. California Privacy Rights (CCPA)

If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) provides you with the following rights with respect to your personal information:

To exercise any of these rights, contact us at support@epicentra-llc.com with the subject line "California Privacy Request." We will verify your identity and respond within forty-five (45) days, with a possible extension of an additional forty-five (45) days where reasonably necessary.

For Platform users, California institutions may also request a Data Processing Addendum that addresses CPRA obligations applicable to business-to-business data processing.

9. International Users (GDPR)

Rah-AI: Vantage is primarily designed for use by U.S.-based college athletic programs. However, Epicentra is building toward multi-sport applicability including international leagues and organizations. If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, the following applies:

[Attorney review note: If and when Epicentra formally enters the EEA market (e.g., IPL, European football), a full GDPR compliance review and appointment of an EU representative under Article 27 GDPR will be required.]

10. Children's Privacy

The Website and Platform are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18 without verifiable parental consent, we will take steps to delete that information promptly. If you believe we have inadvertently collected information from a minor, contact us at support@epicentra-llc.com.

11. Your Rights and Choices

Regardless of your location, all users have the following rights with respect to their personal information:

To exercise any of these rights, contact support@epicentra-llc.com. We will respond within thirty (30) days.

12. Security

Epicentra implements technical and organizational security measures appropriate to the nature of the data we process, including:

Epicentra is not currently SOC 2 Type II certified. We will notify affected Institutions and, where required by law, affected individuals, in the event of a data breach affecting personal information, in accordance with applicable breach notification laws.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Platform, or applicable law. For material changes, we will provide at least fourteen (14) days' notice to Platform users via email or in-platform notice before the changes take effect. Website visitors will be notified via an updated date on this page. The version history of this Policy is maintained and available upon request at support@epicentra-llc.com.

14. Contact

For all privacy inquiries, data subject requests, Data Processing Addendum requests, or general questions about this Policy, contact Epicentra LLC at support@epicentra-llc.com.

Our Terms of Service are available at epicentrallc.com/legal/tos.html.