Privacy Policy – Campus Guardian Angel

1.1

In this Privacy Policy, the following capitalized terms have the following meanings:
— Applicable Data Protection Laws mean and include the privacy laws applicable to you and us including but not limited to CCPA, EU GDPR, TDPSA, UK GDPR.
— Anonymized/Anonymous/de-identified information mean the same as ascribed in Applicable Data Protection Laws.
— CCPA means California Consumer Privacy Act (California Civil Code Section 1798.100 et seq.).
— Contact Details means the contact details provided in Section 17 below.
— Data Controller means the same as ascribed in Applicable Data Protection Laws.
— Data Processor means the same as ascribed in Applicable Data Protection Laws.
— Data Subject means the same as ascribed in Applicable Data Protection Laws.
— EU GDPR means European Union General Data Protection Regulation (Regulation (EU) 2016/679).
— Non-personal Information means information that does not relate to a person and/or cannot be used to identify a person.
— Personal Information/Data means the same as ascribed in the Applicable Data Protection Laws.
— Services mean the provision of our service by way of the Site or any other services, online or offline, it shall have the same meaning as ascribed in the Terms.
— Site means our website https://www.campusguardianangel.com/ or any landing page, app, platform and any other User interface offered by us, including, without limitation, surveys, correspondence and/or marketing activities under the name “Campus Guardian Angel”.
— Terms means the Terms of Services applicable to the Users as accessible at https://www.campusguardianangel.com/termsofservice.
— TDPSA means Texas Data Privacy and Security Act (Tex. Bus. & Com. Code § 541.001 et seq. (2023))
— User, you or your means you and/or any user of the Services, and includes any entity which you are employed, affiliated or contracted with, and any other employee, officer, agent, contractor or advisor of that entity.
Any capitalized terms, used but not defined herein, shall have the same meaning ascribed to them under the Terms.

2.1

We may collect Personal Information about you when you use the Site, register on the Site online, register/subscribe for the Services online or offline, procure the Services, or interact with us in any way.

2.2

Information you provide to us: We collect all information that Users voluntarily provide to us while using the Site, procuring the Services or interacting with us by any other means including, without limitation, surveys, correspondence and/or marketing activities. This includes information provided:

2.3

Information we automatically collect: We also automatically collect certain technical data that is sent to us from the computer, mobile device and/or browser through which you access the Site (Automatic Data). Automatic Data, includes without limitation, a unique identifier associated with your access device and/or browser (including, for example, your Internet Protocol (IP) address), characteristics about your access device and/or browser, statistics on your activities on the Site, details of the Services we have supplied to you or that you have enquired about, including any additional information necessary to deliver those Services and respond to your enquiries, information about how you came to the Site or date/time stamps associated with usage. We may also work with third-party partners to employ technologies, including the application of statistical modelling tools, which permit us to recognize and contact you across multiple devices. We collect Automatic Data based on your consent which was granted to us by you when you registered as a User and accepted this Privacy Policy.

2.4

Information we obtain from others: We may also collect or receive Personal Information from third party sources, such as other Users, suppliers, public sources, businesses with which you interact with or otherwise seek to obtain services from, businesses with which we offer co-branded services, service providers retained to perform Services on our behalf, social media providers, consumer reporting agencies or other third-party integrations and may combine this information with other personal information we maintain about you. If we do so, this policy governs any combined information that we maintain in personally identifiable format.

2.5

Non-Personal Information: When you interact with the Site, we may collect Non-Personal Information. The limitations and requirements of this Privacy Policy on our collection, use, disclosure, transfer and storage/retention of Personal Information do not apply to Non-Personal Information. When you register to the Site or otherwise submit Personal Information to us, we may associate other Non-Personal Information (including Non-Personal Information we collect from third parties) with your Personal Information. At such instance, we will treat any such combined data as your Personal Information until such time as it can no longer be associated with you or used to identify you.

2.6

Aggregated Information: Personal information does not include aggregate or Anonymous information. Aggregate information is information that we collect about a group or category of products, services, or users that cannot be linked back to any particular individual(s). We may use and disclose aggregate information, Anonymous information and other non-personally identifiable information, for various business purposes.

2.7

Do Not Track: Your web browser or device may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Like many websites and online services, the Services are not designed to respond to “Do Not Track” signals

2.8

Accuracy of Information: You are solely responsible for accuracy and lawfulness of Personal Data shared by you with us for purposes of processing the information under this Privacy Policy, we have no knowledge about accuracy and lawfulness over the Personal Data that you provide for processing. we absolve ourselves from any liability arising out of inaccuracy or unlawfulness of Personal Data. We shall process the Personal Information in compliance with the Applicable Data Protection Laws

3.1

We may collect, hold, use and disclose your Personal Information for the following purposes:

3.2

We may also disclose your Personal Information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymized consumer insights so that we can better understand your preferences and interests, personalize your experience and enhance the Services that you receive.

3.3

The information we collect is not distributed, sold or leased to third parties for commercial purposes, except to provide Services you have requested or for other purposes when we have your permission or when we are obliged to do so.

4.1

We and/or our carefully selected business partners may send you direct marketing communications and information about the Services offered by us. You consent to the usage of your Personal Information for direct marketing under this section with the acceptance of this Privacy Policy. This may take the form of emails, SMS, mail or other forms of communication, permitted under Applicable Data Protection Laws. You may opt-out of receiving marketing materials from us by emailing us on the Contact Details provided below, or by using the opt-out facilities provided (e.g., an unsubscribe link).

4.2

We may also use third-party technology through the Site to collect and use data in connection with interest-based advertising. These third-party ad technology companies and advertisers may use, store, or access cookies, web beacons, and other storage technologies to collect or receive information from the Site and elsewhere on the internet and use that information to provide advertising services to us, including interest-based advertising or advertisements targeted to your interests.

4.3

We may use certain third-party web analytics services, including Google Analytics, through the Site to help us understand and analyze how visitors use the Site and to serve ads on our behalf across the internet. We have implemented Google Analytics Advertising features such as behavioral reporting, user segment analysis, and device reporting. To find out more about how these third-party analytics services manage the privacy of information in conjunction with delivering ads online, and how to opt-out of information collection by these networks, please visit: http://www.youradchoices.com, http://www.aboutads.info/appchoices, or http://www.networkadvertising.org. For more information on how Google Analytics uses data collected through the Website, visit: www.google.com/policies/privacy/partners/. To opt out of Google Analytics cookies, visit: http://www.google.com/settings/ads and https://tools.google.com/dlpage/gaoptout/.

5.1

We may disclose Personal Information for the purposes described in this Privacy Policy to:

6.1

As a part of our Services, we offer products, features, or tools powered by AI, machine learning or similar technologies. These tools are designed to enhance your experience and provide you with innovative solutions.

7.1

We may collect Personal Information about you when you use and access our Site. While we do not use browsing information to identify you personally, we may record certain information about your use of our Site, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer, for our internal evaluation purposes.

7.2

We also use cookies, web beacons and other tracking technologies to collect certain information about your equipment, browsing actions, and patterns. Below we describe what are cookies and web beacons, why we use cookies and web beacons, the types of cookies and web beacons that we use as well as what you can do in order to manage and delete cookies and web beacons.

(a)

Cookies are small text files that websites often store on computer hard drives or mobile devices of visitors to their websites. A cookie contains a unique number, which is used to recognize your computer or mobile device when you return to our Site. Cookies can remain on your computer or mobile device for different periods of time. The cookies can be either "persistent" cookies or "session" cookies. Persistent cookies are stored by a web browser and remain valid until a set expiration date. Session cookies only exist while your internet browser is open and are automatically deleted once you close your browser.

(b)

Web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) are small electronic files contained on pages of websites that permit companies to count users who have visited certain webpages on a website and are used for other related website statistics (e.g., recording the popularity of certain website content and verifying system and server integrity).

7.3

We use a variety of cookies, web beacons and other tracking technologies for different purposes. Specifically, we use cookies and web beacons to enhance the experience of our visitors to our Site (for example, by remembering your preferences and letting you navigate between pages efficiently) and to better understand how our Site is used. Cookies may tell us, for example, whether you have visited our Site before or whether you are a new visitor.

7.4

We may also use cookies to enable us to collect data that may include Personal Information. For example, where a cookie is linked to your account, it may be considered Personal Information under Applicable Data Protection Laws. We will handle any Personal Information collected by cookies in the same way that we handle all other Personal Information as described in this Privacy Policy.

7.5

We use both first-party and third-party cookies and web beacons. First-party cookies and web beacons are cookies and web beacons that are served directly by us to your computer or mobile device. Third-party cookies and web beacons are served by a third-party service provider on our behalf. Third-party cookies are most commonly used for advertising and analytics purposes.

7.6

There are four categories of cookies and web beacons used by us. Specifically, we use essential, performance, functionality and advertising cookies and web beacons.

7.7

It is your choice as to whether or not to accept cookies. Most browsers allow you to configure the browser settings so that cookies from websites cannot be placed on your computer or mobile device. If you choose not to accept cookies, then you may be able to continue browsing our Site but we may not be able to provide you with certain features.

8.1

We may hold your Personal Information in either electronic or hard copy form. We take reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorized access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your Personal Information. However, no security system is impenetrable, and we cannot guarantee 100% security of your Personal Information.  In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate and required, notify those individuals whose information may have been compromised and take other steps, in accordance with any Applicable Data Protection Laws.

9.1

Our Site and Service is hosted at Webflow. Currently the information we obtain through the Services will be transferred to, processed, and stored on our servers in the Webflow. (If you visit from the European Union, UK or other regions outside the US, your information may be transferred and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction).

9.2

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

9.3

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and Personal Information.

10.1

Ordinarily, we will retain your Personal Information as long as you are registered to the Site as a User, and for a period as permitted under the applicable laws following you closing your account or for the normal course of deletion from the servers unless an erasure of the Personal Information is requested by you in accordance with the Applicable Data Protection Laws.

10.2

You may close your account by contacting us at Contact Details.

11.1

Links: Our Site may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

11.2

Personal Information Provided to Others: This Privacy Policy does not apply to any Personal Information that you provide to another User or visitor through the Site or through any other means, or information posted by you to any public areas of the Site.

12.1

You can reach out to us at Contact Details in connection with this Privacy Policy and regarding our role as Data Controller and Data Processor. You can send your specific requests for exercising your rights which relate to your Personal Information under the Applicable Data Protection Laws. We may also need to verify your identity when you make any request for availing your rights under this section.

12.2

As a Data Subject of European Economic Area, you shall have the rights under EU GDPR with our organization as Data Controller and Data Processor of your Personal Data.

12.3

We will consider and respond to all requests in accordance with the Applicable Data Protection Laws.

13.1

If you reside in California, then in addition to the rights described above, you have been provided certain additional rights with respect to your Personal Information under the CCPA. These rights are discussed in Sections 13.3 to 13.7.

13.2

We collect your information for the purposes described in this Privacy Policy, which include “business purposes” under the CCPA.

13.3

Right to Know
You have a right to request and know the following information about you in writing:

13.4

Right against Discrimination
You have a right to receive the same services and price as other Users and cannot be discriminated against for exercising any of the rights described in Sections 13.3 to 13.9. We will not discriminate against you in any manner for exercising any of these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

13.5

Right to access your Personal Information
You have the right to request access to the categories of Personal Information that we have collected about you in the last 12 months. We can provide you a with a copy of your personal information (whole or part) within 45 days of receiving a written request from you on the Contact Details provided below. 
To clarify, in the preceding 12 months, we collected the following categories of Personal Information about you: 

13.6

Right to ask for deletion of your Personal Information
You have the right to ask us to delete any Personal Information that we have collected about you without any additional cost by sending a written request on the Contact Details provided below. This right is subject to certain exceptions and we may retain your Personal Information where we cannot verify your request, or where we need to retain the Personal Information to comply with legal obligations under the Applicable Data Protection Laws, etc.

13.7

Right to correct
You have the right to request us for correcting any inaccuracy or outdatedness of your Personal Information without any additional cost by sending a written request on the Contact Details provided below.

13.8

Right to obtain a copy
You have the right to request us to provide you with a copy of the Personal Information that you have previously shared with us.

13.9

Right to opt-out of having your Personal Information sold
You have the right to opt-out of having your Personal Information sold. To clarify, we do not sell your Personal Information.

13.10

Shine the Light
California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83).

13.11

Financial Incentives
We do not offer financial incentives or price or service differences to consumers in exchange for the retention or sale of a consumer’s Personal Information.

13.12

How do you exercise your rights?
Users residing in California may exercise these rights by reaching out to us at Contact Details. Please note that we may ask you for proof of account ownership and, or identity before completing your request. We will only use such information to verify your identity, and for fraud prevention or security purposes.

13.13

Authorized Agents
In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in this Section 13. We can verify the authorized agent’s authority to act on your behalf by:

14.1

You may have additional rights based on the state/country that you reside in. Please reach out to us on the Contact Details mentioned below to exercise your rights based on applicability of the Applicable Data Protection Laws.

15.1

We do not knowingly solicit data from children or knowingly market to children. We do not knowingly request or solicit Personal Information from anyone under the age of 13. If you are under the age of 13, please do not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. In the event that we receive actual knowledge that we have collected such Personal Information without the required and verifiable parental consent, we will delete that information from our database as quickly as is reasonably practical.

15.2

In case where the Personal Information relates to a child who is below the age of 16 years then such processing of Personal Information shall be lawful only if and to the extent that consent is given or authorized by the holder of parental responsibility over the child. We shall secure parental consent in circumstances where Personal Data of children below the age of 16 years is shared.

16.1

If you think we have breached any Applicable Data Protection Laws, or you wish to make a complaint about the way we have handled your Personal Information, you can contact us on the Contact Details provided below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to your complaint within a reasonable period of time or as per the Applicable Data Protection Laws. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps that you can take.

17.1

For further information about our Privacy Policy or practices, or to access or correct your Personal Information, or make a complaint, please contact us as below: