Last
Updated: August 8, 2018
1.
Introduction
CampusEd
values the trust our users and customers place in us when they give us access
to their personal data. The Privacy Policy describes how we work to maintain
that trust and protect that information.
In particular, this Privacy Policy details our collection, use and disclosure of
personal and non-personal data you give to CampusEd when you access or use CampusEd’s online and/or mobile services and websites, and
software provided by CampusEd on or in connection with such services or
websites (collectively, the “Site”).
1.1
The CampusEd Entities Responsible for Your Information
All
references to User and Employer are defined as provided for in
the CampusEd Terms of Service Introduction.
With respect
to Users, for the purposes of this Privacy Policy, “CampusEd” or “we” means
CampusEd, Inc. if you are a User located in the United States.
With
respect to Employers, “CampusEd” or “we” means CampusEd, Inc. if you are an
Employer located in the United States.
1.2
Personal Data and Non-Personal Data
Personal
data (“Personal Data”) refers to any information that identifies you as a
specific individual, and non-personal data (“Non-Personal Data”) refers to any
information that does not identify you as a specific individual. Please note
that, at all times, CampusEd will adhere to the applicable statutory definition
in determining what is and is not Personal Data for the purposes of this
Privacy Policy. Where this Privacy Policy refers to “information” or “your
information” this may include both Personal and Non-Personal Data.
1.3
The Scope of CampusEd’s Privacy Policy
This
Privacy Policy covers only data that we collect through the Site, and not any
other data collection or processing, including, without limitation, the data
collection practices of any affiliate or other third party, including any
third-party operators of web pages to which the Site links, and any information
that we collect offline or through any websites, products, or services that do
not display a direct link to this Privacy Policy.
Occasionally,
we may refer to this Privacy Policy in notices on the Site, including special
purpose web pages, mobile applications, or other resources, for example, if we
invite you to submit ideas to improve the Site. This Privacy Policy applies to
information collected by us through such special purpose resources, as modified
in the particular notice (e.g., with respect to the types of data collected or
our uses or disclosures of such information). CampusEd may amend this Privacy
Policy at any time.
1.4
Changes to the Privacy Policy
Please
review the “Last Updated” legend at the top of this page to determine when this
Privacy Policy was last amended. Any changes to this Privacy Policy will become
effective on the “Last Updated” date indicated above. By using the Site or
providing information to us following such changes, you will have accepted the
amended Privacy Policy. If CampusEd is going to use Personal Data collected
through the Site in a manner materially different from that stated at the time
of collection, then CampusEd will notify users via email and/or by posting a
notice on CampusEd’s Site for 30 days prior to such
use or by other means as required by law.
2.
Information Collected
You
provide different types of information in order for CampusEd to provide our
services, products and features to you.
2.1
Information You Provide to CampusEd
–
From Your Account
We
collect data from you when you create a CampusEd account, request information,
subscribe for a service, participate in a survey, post a rating or review, post
a question or answer, post a resume, complete a CampusEd assessment, complete
an assessment from a third-party issuer via CampusEd, complete online resource
content via CampusEd, earn a digital badge, upload content or otherwise
actively send us data on our Site. This may include, but is not limited to,
your user name, password, first and last name, email address, telephone number
(including mobile phone number), street address, gender, occupation, interests,
messages you send to users, and any other data included in a submitted profile
or resume, including but not limited to application materials and answers to
screener questions submitted to Employers through CampusEd and answers you give
to any questionnaires sent to you, which you answer.
–
Through Your Activity on CampusEd
In
addition, as part of the standard operation of the Site, CampusEd may collect
and analyze information from your computer or mobile device and actions taken
on the Site, including, but not limited to, your resume, your searches on
CampusEd, content reviewed or completed, the titles of resources, badges and/or
jobs you search, click on or apply to, where those jobs are located,
wage/salary interest or experience, the general wage/salary range or experience
level of the jobs you view (where indicated), your activity time on the Site
and each page, page views, clicks, taps, session activity, browser type,
operating system, type of device, MAC address, IP address and the domain name
from which you accessed the Site.
–
When Providing Employer Information
If you
are an Employer, CampusEd may request that you provide certain Personal Data to
CampusEd in order to verify your account. This information may include, but may
not be limited to, your Federal Employer Identification Number (EIN), Business
Registration information, or a utility bill, the name and email address of an
Employer representative.
This
information will be used for internal purposes only, subject to any request by
law enforcement or a court order. In connection with chargeable services, we
will also collect payment information (e.g., the last four digits of credit
card numbers and related verification information). Please note that CampusEd
only has access to the last four digits of Employer credit card numbers, and
does not store full credit card numbers.
2.2
Information Collected When You Apply for Jobs or Access CampusEd from Some
Third-Party Websites
–
When You Apply to Jobs on Some Third-Party Sites
CampusEd
may also collect information about web sites and web pages you visit through
our mobile software and this may include third-party sites and web pages. We do
this in order to allow a User to keep a record of particular Job Posts of
interest, to detect a job application form on a third-party website to give a User
the option to auto-fill parts of the form using CampusEd Resume, or to confirm
an application. This capability also allows CampusEd to learn about
what types of jobs and CampusEd product features are of interest to you,
so that we can provide you with improved Job Post searches, Job Post
recommendations and product features.
–
When You Log In or Use CampusEd from Some Third-Party Sites
You may
also create an account or log in to your CampusEd account using third-party
websites including, but not limited to, Facebook or Google. If you do not
already have a CampusEd account but log in to CampusEd using your Facebook or
Google account, this creates a CampusEd account using the same email address
used in your Facebook or Google account. If you agree to provide this
information to CampusEd, Facebook or Google will authenticate you and redirect
you to CampusEd’s Site. Please note, when you log in
to CampusEd using your Facebook or Google account, Facebook or Google will
cookie you in order to authenticate you as a Facebook or Google user.
By
accessing CampusEd through your Facebook or Google account, you understand that
Facebook or Google will share certain data detailed above in this paragraph for
the purposes of authentication to permit you to access our Site in a secure
manner. You may stop this at any point from your Facebook or Google account.
This information will be considered CampusEd account information for purposes
of your use of the Site.
You have
the ability to disable the connection between your Facebook or Google account
and your CampusEd account at any time by accessing your privacy settings on
your Facebook or Google account. Facebook may also ask for your permission to
share certain other details with CampusEd, including but not limited to your
name, profile picture, public profile information, and email address.
PLEASE
NOTE THAT YOUR RELATIONSHIP WITH FACEBOOK OR GOOGLE OR ANY OTHER THIRD-PARTY
WEBSITE IS GOVERNED SOLELY BY YOUR AGREEMENT WITH SUCH THIRD-PARTY WEBSITE.
2.3
Any Other Personal Data CampusEd May Receive from Third Parties
Any
Personal Data that CampusEd may obtain from other third-party sources will be
processed by CampusEd in accordance with this Privacy Policy and all applicable
laws.
2.4
Storage of Your Information
CampusEd
shall retain users’ Personal Data to the extent such retention is adequate,
relevant and limited to what is necessary for the purposes for which they are
processed. In particular, CampusEd shall not retain Personal Data for any
longer than necessary for the purposes of performing the processing outlined in
this Privacy Policy.
If you
create a CampusEd account, your information may be collected and stored in a
manner that connects to your account email address. CampusEd may also create
and assign to your device an identifier that is similar to an account number.
We may collect the name you have associated with your device, device type,
telephone number, country, and any other information you choose to provide,
such as user name, email address, or zip code. For example, while using a
mobile device to access CampusEd, CampusEd may provide a User with relevant job
postings that are located within the same zip code as where this activity is
taking place. The collection of this data is solely used in accordance with the
purposes outlined in sections 4, 5 and 9 of this Privacy Policy, to the extent
applicable.
CampusEd
may also store the information detailed in this section 2 of the Privacy Policy
on its equipment or the equipment of third parties that CampusEd has a
relationship with. Such storage services will be governed by appropriate
protections, as required by applicable rules.
2.5
What Personal Data is Required
CampusEd
will indicate to you at the point of provision as to whether or not particular
Personal Data provided by you is required in order to provide particular
CampusEd services or features to you. Where Personal Data that is required is
not provided by you then the particular feature or service may not be available
to you.
2.6
The Legal Basis on Which CampusEd Collects Your Personal Data
CampusEd
collects and processes your Personal Data on the basis of different legal
grounds, depending on the nature of the Personal Data being provided and the
type of processing involved. More information is provided on this here.
–
Performance of a Contract
Most of
the Personal Data processed by CampusEd is performed on the basis that it is
necessary for the performance of our agreement with you, or in order to take
steps at the request of the user prior to entering such an agreement. An
example of this would be where CampusEd matches Users with Employers.
–
Legitimate Interest
A second
ground relied upon by CampusEd for other types of processing of your Personal
Data is that it is necessary for the purposes of legitimate interests pursued
by CampusEd. Such legitimate interests will include where CampusEd sends you
marketing about our products and services, where we believe you have a
reasonable expectation that we will perform a particular type of processing on
your behalf, or where such processing is strictly necessary for fraud detection
and prevention. CampusEd will only rely on such a ground where an assessment
has been performed balancing the interests and rights involved and the
necessity of the processing in order to provide our services, products and
features to you.
–
Compliance with a Legal Obligation
A third
ground relied upon for certain types of processing is that it is necessary in
order to allow CampusEd to comply with a legal obligation. An example of this
would be where CampusEd is required to retain business records for fixed
periods of time in order to comply with local legal requirements.
–
Consent
Finally,
in certain limited situations, CampusEd relies on your consent in order to
process your Personal Data. Where CampusEd requires your consent in order to
collect and process certain Personal Data, we seek your consent at the time of
provision, and such processing will only be performed where consent is secured.
For example, your consent will be sought where you provide your location when
you use CampusEd’s Job Spotter, or in certain
instances where you initiate a job alert with CampusEd (detailed in section 4
of this Privacy Policy).
3.
Limitation of Use or Disclosure of Personal Data
3.1
Where a User Wants to Close a User Account
When a User
closes an account, the User will no longer have access to any of the data we
make available under that account name, including but not limited to, search
history, job search preferences, saved jobs, jobs the User has applied to, job
alerts, resume, and any other data associated with the account. If the User
uses the same email address to set up a new account, this data from a previous
account will not become available to the User again. Please also note that
closing your User account may result in you losing access to all CampusEd
products and the ability to utilize the “Log in with CampusEd” feature found on
certain third-party sites.
CampusEd
reserves the right to keep any materials in a closed account as necessary to
preserve and protect its rights to the extent permitted by law (for example, to
preserve records of a dispute) or to comply with its obligations under local
law (for example, if requested to retain by law enforcement). A closed account
does not mean that all of the data is expunged from the CampusEd systems,
although it will not be readily available under the User’s original account
name. When the User presses the close account button on the dashboard, CampusEd
will begin to process that instruction within 24 hours and will have completed
the operation within 40 days.
If a User
wishes to access or delete their Personal Data held by CampusEd, they should
follow the steps listed in section 10 of this Privacy Policy, and such a
request will be processed in accordance with applicable rules.
3.2
Where an Employer Wants to Close an Employer Account
Employers
may close an account at any time by contacting
CampusEd Customer Support. Please note that
CampusEd must preserve business records pertaining to that account to comply
with its obligations under law. Alternatively, if an Employer agent wishes to
access or delete their Personal Data held by CampusEd, they should follow the
steps listed in section 10 of this Privacy Policy, and such a request will be
processed in accordance with applicable rules.
3.3
Where a User Wants to Delete a Job Application
If a User
wants to delete a job application performed on CampusEd’s
Site, they are advised to contact the prospective Employer directly to request
deletion of their application. For job applications which you, the User submit
through CampusEd (including the use of a CampusEd Apply button) to an Employer,
(with related materials submitted), please note: 1) that your applications and
materials may be controlled by an Employer; 2) we may direct you to that
Employer for Personal Data deletion requests where that Personal Data is held
by that Employer; and 3) CampusEd depends on the Employer or the Employer’s
agent to provide CampusEd with the correct destination for all applications.
3.4
Where the Employer Contact Details Provided to CampusEd Are Incorrect
In the
event that the electronic destination provided to CampusEd is incorrect, your
application materials will not be sent to the intended recipient of the
application. CampusEd has no liability for such applications. If you do not
wish to send your application materials in this manner, you should send them
directly to the Employer.
3.5 CampusEd Messaging
When communicating through CampusEd’s
message system, you are sending and receiving messages from other CampusEd
users including Employers/Recruiters. You understand that you retain no ownership
rights in these messages (which are specific to Employers’ Job Posts) nor the repository
where they reside, as both the message and the repository are owned by
CampusEd. However, CampusEd’s message system will
show the name associated with your account or job application in the “To:” or
“From:” field.
Please
also note that if these message proxy and relay services at some point in the
future depend on the functionality of third-party providers, there may be
technical delays on the part of those service providers.
3.6
Minimum Age of our Users
The Site
is not for use by anyone under the age of 16. To use the Site you agree that
you must be the minimum age (described in this paragraph below) or older.
The
minimum age for these purposes shall be 16, however if local laws require that
you must be older in order for CampusEd to lawfully provide the services in the
Site to you then that older age shall apply as the applicable minimum age. In
all jurisdictions outside the European Union, if you are under the age of 18 or
the age of majority in your jurisdiction, you must use CampusEd under the
supervision of your parent, legal guardian or responsible adult. CampusEd
adopts a range of measures to try to ensure that we do not accept individuals
who do not meet the minimum age and any other applicable age
requirements. If you do not satisfy these age requirements, please
email support@campused.com for more
information.
4.
Purposes, Uses and Disclosures of Information
We may
use any information collected pursuant to this Privacy Policy, including
Personal Data, for the purposes set forth in this sections 4, 5 and 9 of this
Privacy Policy, to the extent applicable. CampusEd uses such information to
help Users find jobs and to help Employers find candidates. In order to do this
we use your Personal Data to:
1)
provide our services, products and features to you, to help Users find jobs and
Employers find candidates;
2) to
measure and improve those services, products and features; and
3) to
protect our users and provide them with customer support.
More
detail on these purposes, uses and disclosures of your information is set out
below.
4.1
Creating an Account, Sending You Job Alerts and Other Promotional Materials
If and to
the extent permitted by applicable law, CampusEd may use your contact
information to (i) create an account; (ii) send you
job alerts; (iii) send you content suggestions; and (iii) send you
information about CampusEd, including promotional materials. CampusEd may use
third-party partners to perform these activities on CampusEd’s
behalf.
A job
alert is defined as an email sent to you that you sign up for containing Job
Posts in response to a search query you have run (“Job Notification”). Job Notifications
may also include jobs that CampusEd recommends for you, CampusEd Targeted Ads,
companies you may be interested in viewing, or other actions you may want to
take on the Site.
A content
suggestion is defined as an email sent to you that you sign up for containing Learning
Plan, Resource or Badge titles in response to a search query you have run or
prior selections you have made (“Content Suggestion”). Content Suggestions may
also include Learning Plan, Resource or Badge titles that CampusEd recommends
for you, CampusEd Targeted Ads, new content/resources you may be interested in using,
or other actions you may want to take on the Site.
CampusEd
may also share your information with third parties (including operators of
third-party websites and/or social networking sites) in order to show you
targeted advertisements and other content that has been customized for you.
Such advertisements will only relate to CampusEd’s
services, products, and features, all of which focus on helping Users find jobs
and Employers find candidates. If you wish to opt out of receiving any
marketing messages from CampusEd please see section 14 of this Privacy Policy.
4.2
Giving You Relevant Search Results and Recommended Jobs
In order
to optimize our services, products and features for you, CampusEd may use your
previous search and browsing history (e.g. the jobs you click on), content use
history, or application materials and answers to screener questions, to
identify you and determine relevant search results and provide you with recommended
jobs or reach out to you about additional content and/or jobs you may be
interested in. We may also use demographic and/or profile data to tailor your
experience on the Site, to show you content that CampusEd thinks you may be
interested in, and display content according to your preferences. CampusEd
may return different results for the same search query and has full discretion
with respect to the content and/or Job Posts it presents in response to any
particular search.
4.3
Your Contact Information
When you
give CampusEd contact information (such as your name and email address) and
other forms of Personal and Non-Personal Data, you agree that CampusEd may
utilize this information for the purposes outlined in sections 4, 5 and 9, to
the extent applicable. In particular, you agree that CampusEd may, as part of
its services to you, communicate with you, or initiate communication with you
on behalf of a third party, through your CampusEd account or through other
means such as email, telephone (including mobile phone), or postal mail,
including through the use of contact information that you may provide to
CampusEd or that CampusEd may otherwise obtain from third-party resources.
4.4
Your Resume Information
Your
information, including Personal Data, gets placed on the Site when you upload,
create, or edit a resume. CampusEd reserves the right to charge third parties a
fee for accessing your information, including Personal Data, as part of CampusEd’s services. At your direction, CampusEd may also
send your resume to third parties if you choose to apply for a Job Post. The
extent to which your information is made available to third parties depends on
the privacy settings you choose on CampusEd. When a User creates a resume on
CampusEd, they are given the option to make their resume public or private.
This is detailed below.
–
Private Resumes
Private
resumes are only made available to those to whom the User has initiated an
application or provided their resume. Where this occurs, you make your resume,
your name and other Personal Data that you place on your resume available to
third parties. Those third parties may be interested in you as an employee, and
may forward your resume to other third parties.
–
Public Resumes
Public
resumes are available to your CampusEd connections as well as anyone with
access to CampusEd’s resume search application, in
order to increase the visibility of that resume and help CampusEd find you a
job (“Primary Resume”). Where this occurs, you make your Primary resume, your name
and other Personal Data that you place on your resume available to third
parties. Those third parties may be interested in you as an employee, and may
forward your resume to other third parties.
If you
add a Primary Resume to your CampusEd profile, this may be crawled by, and
displayed through search engines when someone searches for your name. This
means that third parties can view the Personal Data contained in your resume
and you may receive unsolicited contact from parties unaffiliated with CampusEd
and for whom CampusEd has no responsibility. If you designate a Primary Resume
on CampusEd, please note that although CampusEd expressly prohibits the
scraping of its Site any resume you post publicly or designate “Primary” is
public information and the content may be copied by a third party in violation
of these terms.
For
resumes you designate as “Primary,” you also authorize CampusEd to remove your
name from your Primary Resume, in certain instances.
–
Changing Your Resume Privacy Settings
You have
the option to designate one resume as Primary, or public when you create your
resume on CampusEd. You may adjust this at any point by selecting an alternate
resume as Primary and/or editing your privacy settings on CampusEd. Where you
adjust your resumes from Primary to Non-Primary, CampusEd does not warrant how
often third-party search engines will update their caches, which may continue
to contain your resume information.
4.5
Matching Users With Employers
You
acknowledge that CampusEd may determine whether the words of your resume or any
other individuals’ resume match the words of certain job descriptions, and vice
versa, in order to improve the Site or any other CampusEd product or service
(including by displaying or otherwise making available potentially relevant job
descriptions and resumes to Users and Employers).
CampusEd
may also provide information collected pursuant to this Privacy Policy,
including Personal Data, to Employers that may be interested in contacting you.
By applying to a job, answering screener questions, providing your contact
information to show interest in a job, or by replying to a message from an
Employer, you agree to the disclosure of your information to that
Employer. CampusEd may also provide the results of any CampusEd and/or Third-Party
Assessments you complete to Employers, where you agree to such provision at the
time of taking such an assessment.
If you
have a CampusEd account or a CampusEd-hosted resume, you agree that CampusEd
may contact you or suggest you or your public resume to Employers that might be
interested in a person who matches your behavior on CampusEd.
In
addition, if you are located in the United States and you designate your Resume
as Primary, this means that CampusEd may share all of the aforementioned information
about you with recruiters working for or on behalf of Employers. If you do not
wish to share such information, you may set your Resume to private.
4.6
Sending Messages on CampusEd
CampusEd
provides two-way message proxy and message services to the users of CampusEd
products. By utilizing this CampusEd message function, you acknowledge that you
are asking CampusEd to send these messages on your behalf. This includes your
resumes, cover letters, applications, messages, questionnaire answers, responses,
offer letters and other materials.
We
monitor, review, store and analyze such content, including via automated means,
for data analysis, quality control, and to improve the Site or any other
CampusEd product or service. Examples of such improvements would be optimizing
our search results, improving Job Posts, provide you with personally relevant
product features, and preventing fraud and spam.
4.7
Preventing Fraud and Spam
CampusEd
may also use information collected pursuant to this Privacy Policy to help
diagnose problems with the Site and CampusEd’s
service, to prevent potentially fraudulent or illegal activities, and to
protect individuals from other activities that may be detrimental to you or
others. CampusEd may investigate and disclose information from or about you or
your use of CampusEd if we have a good faith belief that such investigation or
disclosure (a) is reasonably necessary to comply with legal process (including
subpoenas, search warrants, court orders) and law enforcement instructions and
orders; (b) is helpful to prevent, investigate, or identify possible
wrongdoing in connection with the use of the Site; or (c) may protect our
rights, reputation, property, safety, or that of the public; or (d) as
necessary to meet national security requirements.
For
example, CampusEd is subject to the investigatory and enforcement powers of the
Federal Trade Commission in the United States, the Data Protection Commission
of Ireland, and many other regulatory bodies.
We may
use a variety of methods to detect and address anomalous activity and screen
content to prevent abuse such as spam or fraud. However, such detection methods
are not perfect and false positives may occur. These efforts may on occasion
result in a temporary or permanent suspension or termination of some functions
for some users.
–
Preventing Fraud and Spam in Messages
CampusEd
also reserves the right to drop messages from our message system that CampusEd
determines do not adhere to Site Rules or any of the terms of this agreement.
CampusEd further reserves the right to conduct investigations to determine
whether you are perpetrating a scam, spamming CampusEd or its users, or
otherwise conducting fraudulent activity on CampusEd by various means,
including but not limited to investigating your functionality by setting up
profiles and names that belong to CampusEd. CampusEd also reserves the right to
turn over any information gathered via such investigations to the police or
other third party if CampusEd has a good faith belief that you are using the
Site in violation of these terms.
CampusEd
reserves the right to verify and confirm the identity of any party associated
with a message. This includes but is not limited to verifying the identity of
the sender of a message with the Employer agents associated with the message.
4.8
Facilitating Payment
If you
provide credit, debit or other payment card and related details to us in order
to make a payment, CampusEd will use such information only for the purpose of
processing the payment (e.g., the last four digits of credit card numbers and
related verification information). Any credit card and related billing and
payment information that you provide to CampusEd may be shared by CampusEd with
companies who work on CampusEd’s behalf, such as
payment processors and/or credit agencies, solely for the purposes of checking
credit, effecting payment to CampusEd and servicing your account.
4.9
Automated Processing of Your Personal Data
In order
to optimize the performance of the CampusEd Site and services for users,
CampusEd performs automated processing of Personal Data evaluating certain
specific aspects relating to a user, in particular to analyze or predict
aspects concerning a user’s personal preferences or interests in terms of CampusEd’s Site and services. Where it occurs, such
processing is carried if it is necessary for the performance of our agreement
with our users, to allow CampusEd to provide its services to Users and
Employers, or in other cases on the basis of a user’s consent.
For
example, this allows CampusEd to match Users with Employers effectively, or
provide Users with Job Posts they are more likely to be interested in. Such
processing is subject to the safeguards detailed in this Privacy Policy and
users may contact support@campused.com to get further information about this or to
contest the decision generated by said automated processing.
4.10
Transfer of Information to CampusEd Affiliated Entities
Any
information shared by you with CampusEd may be shared with or transferred to
any CampusEd affiliated entity, no matter where located, for the purpose of
providing you services and improving the Site. This includes CampusEd
affiliated entities located outside the European Union (“EU”) or Switzerland.
Such
transfers are performed in full compliance with applicable data protection
rules and subject to appropriate safeguards, primarily through the use of
extensive data protection agreements, in order to ensure adequate protection of
users’ Personal Data. The services provided to you and the functionality
of the Site could not be provided without such a transfer. If you do not wish
your information to be transferred in this way you should not use this Site.
4.11
Transfer of Information to Third Parties
–
Transfers to Employers
Employers
agree to comply with all their responsibilities under applicable data
protection rules with respect to the collection, processing and storage of
Personal Data, as well as providing adequate protection of all data subject
rights provided for under all applicable data protection rules.
–
Transfers to Service Providers and Vendors
We may
use third parties to perform services in connection with our operations, to
improve the Site and our services, products and features, and to protect our
users. These third parties may include (but are not limited to) service
providers and vendors.
CampusEd
may transfer your Personal Data in limited situations to certain third-party
vendors that assist CampusEd with protecting our users and maintaining the
quality of our services, products and features provided to those users. An
example would be vendors CampusEd uses for fraud detection purposes. Examples
of those vendors include: SiftScience and Emailage.
CampusEd
may also share any credit card and related billing and payment
information that you provide to CampusEd with companies who work on CampusEd’s behalf, such as payment processors and/or credit
agencies, solely for the purposes of checking credit, effecting payment to
CampusEd and servicing your account. Examples of those vendors include: Authorize.net.
In the
course of providing these services, those companies may have access to Personal
Data, and this may involve transfers of such Personal Data to other countries.
Such transfers are only made for the purposes set forth in sections 4, 5 and 9
of this Privacy Policy, to the extent applicable and necessary. Those companies
are also contractually required to treat such Personal Data in accordance with
this Privacy Policy, and in accordance with all applicable laws with respect to
such transfers and any processing performed by those third parties on such
Personal Data.
–
Transfers to Cloud Service Providers
Please
also be aware that we may also use third-party cloud service providers that
provide hosting, data storage and other services pursuant to standard terms and
conditions that may be nonnegotiable; these service providers have
informed us or the general public that they apply security measures they
consider adequate for the protection of information within their system, or
they have a general reputation for applying such measures. However, we will not
be liable (to the fullest extent permitted by law) for any damages that may
result from the misuse of any information, including Personal Data, by these
companies.
–
Transfers of Publicly Available Information
When
users post content on CampusEd in a manner that is intended to make that
content publicly available and searchable by individuals, CampusEd reserves the
right to aggregate and share that information with third parties. For example,
if an Employer posts a job on CampusEd, CampusEd may share that job posting or
information contained within that job posting with third parties, at CampusEd’s discretion and subject to agreement between
CampusEd and any such third parties. CampusEd also reserves the right to share
information aggregated from public sources in this capacity.
–
Third-Party Sites You Link to from CampusEd
You may
also use certain third-party sites or services that you link to from CampusEd’s Site. In such cases, all information you provide
to a third party is provided to that third party and not to CampusEd, and is subject
to the third-party’s privacy policy and terms of service. Please see section 8
of this Privacy Policy titled Links to Third-Party Sites for more information.
–
Transfers of Personal Data for individuals in the EU and Switzerland
Please
see sections 11 and 12 of this Privacy Policy for information related to this.
5.
Additional Uses and Disclosures of Non-Personal Data
In
addition to the other uses and disclosures of information set forth in this
Privacy Policy, and notwithstanding anything in this Privacy Policy to the
contrary, we may use and disclosure, for any purpose, any Non-Personal Data,
except where we are required to do otherwise under applicable law. If we
combine any Non-Personal Data with Personal Data, then we will only use and
disclose such combined information for the purposes described in sections 4 and
9 of this Privacy Policy while it is so combined.
6.
Security
CampusEd
seeks to use reasonable security measures to help protect against the loss,
misuse and alteration of the Personal Data under CampusEd’s
control. No method of transmission over the Internet, or method of electronic
storage, is 100% secure, however. In addition, please note that messages sent
via your web browser, and other similar means of communication with other users,
are not encrypted. Therefore, while we strive to protect your information, we
cannot guarantee its security.
Please
also be aware that we may use third-party cloud service providers that provide
hosting, data storage and other services pursuant to standard terms and
conditions that may be nonnegotiable; these service providers have
informed us or the general public that they apply security measures they
consider adequate for the protection of information within their system, or
they have a general reputation for applying such measures. However, we will not
be liable (to the fullest extent permitted by law) for any damages that may
result from the misuse of any information, including Personal Data, by these
companies. Please see section 11 of this Privacy Policy for liabilities
pertaining to the transfer of Personal Data of individuals in the EU and
Switzerland.
7.
Cookies
“Cookies”
are small pieces of information that are stored by your browser on your
computer’s hard drive. Please see our Cookie
Policy
for further information regarding CampusEd’s
use of Cookies.
8. Links
to Third-Party Sites
The Site
may make available links to other websites. When you click on such links, you
may leave our Site. The Site may also make available Company Pages, which may
contain information provided by third-party Employers.
WE ARE
NOT RESPONSIBLE FOR THE INFORMATION COLLECTION, USE, DISCLOSURE OR OTHER
PRIVACY PRACTICES OF ANY THIRD PARTY, INCLUDING OUR AFFILIATES, THIRD-PARTY
SERVICE PROVIDERS, ANY EMPLOYERS (INCLUDING ANY EMPLOYER THAT PROVIDES A
COMPANY PAGE), ANY THIRD-PARTY SOCIAL MEDIA PLATFORM, ANY THIRD PARTY MAKING
AVAILABLE THE DEVICES OR OPERATING SYSTEMS FOR WHICH THE SITE IS AVAILABLE, AND
ANY THIRD PARTY OPERATING ANY WEBSITE TO WHICH THE SITE CONTAINS A LINK. YOU
MAY HAVE RIGHTS DIRECTLY ENFORCEABLE AGAINST THESE THIRD PARTIES SO YOU SHOULD
CONSIDER THEIR PRIVACY POLICIES TO LEARN MORE.
9.
Acquisitions and Other Reorganizations
Information
collected pursuant to this Privacy Policy, including Personal Data, may be
disclosed to one or more third parties in connection with any change of
ownership or control in CampusEd’s business (whether
by merger, sale, or otherwise), or any other reorganization or joint venture,
or assignment, transfer or other disposition of all or any portion of our
business, assets or stock (including in connection with any bankruptcy or
similar proceeding), and any such information may be used by such third party
in accordance with this Privacy Policy. Equally, information collected pursuant
to this Privacy Policy, including Personal Data, may be disclosed to one or
more third parties in connection with any acquisition or merger carried out by
CampusEd of such third parties.
10.
Exercising Rights With Respect to Personal Data
CampusEd
users that provide their Personal Data in the EU, and those that provide their
Personal Data in any other jurisdictions that adopt laws affording equivalent
protections to those in the EU, may avail of the rights detailed below.
10.1
The Right to Rectify Your Personal Data
CampusEd
users are able to edit and update most of their Personal Data held by CampusEd
on the Site, and if you have any queries or complaints we encourage you to
contact us at support@campused.com.
Alternatively,
if you do not wish to do this you may make a formal request to have CampusEd
rectify any inaccurate Personal Data on your behalf by sending an email to support@campused.com from the email address
associated with your account.
10.2
The Right to Object to or Restrict the Processing of Your Personal Data
If you
have any queries or complaints about how we process your Personal Data we
encourage you to contact us at support@campused.com.
Alternatively,
if you do not wish to do this you may make a formal request to object to, or
restrict, processing of your Personal Data by CampusEd. In order to do so
please send an email tosupport@campused.com from the email
address associated with your account.
10.3
The Rights of Access to and Portability of Your Personal Data
CampusEd
users are able to access most of their Personal Data held by CampusEd on the
Site, and if you have any queries or complaints we encourage you to contact
us at support@campused.com
.
Alternatively,
if you do not wish to do this you may make a formal request to access your
Personal Data held by CampusEd. In order to do so, please send an email to
support@campused.com
from the email
address associated with your account, and paste the following sentence in your
email: “I am requesting to access my personal data.” CampusEd will provide your
Personal Data to you in a portable format to allow it to be transmitted to
third parties.
10.4
The Right to Delete Your Personal Data
CampusEd
users are able to edit and update most of their Personal Data held by CampusEd
on the Site, and if you have any queries or complaints we encourage you to
contact us
here.
Alternatively,
if you do not wish to do this, you may make a formal request delete your
Personal Data held by CampusEd. In order to do so, please email to
support@campused.com
from the email
address associated with your account, and paste the following sentence in your
email: “I am requesting to delete my personal data.” Once your request has been
confirmed, CampusEd will initiate the necessary steps to execute this exercise,
including the deletion of your CampusEd account. Where the deletion request
relates to Personal Data that you previously requested be made public on
CampusEd (e.g. a User posting a public resume), we will make reasonable efforts
to inform any other controllers of this request.
PLEASE
NOTE: by requesting the deletion of your Personal Data, you will no longer be
able to create an account with CampusEd using the same email address. If you
simply wish to close your account, please click the “close my account” button
in your account page.
10.5
Some Limitations
Such rights
of rectification, objection, restriction, access, portability and deletion are
subject to certain limitations, as provided for by applicable laws. Individual
requests will be completed within the time allotted by relevant regulations,
which starts to run from the point of CampusEd confirming your request. Where
permitted, please note there may be a charge for subsequent requests from the
same individual, which will be determined by CampusEd and only imposed to the
extent permitted by applicable law.
11.
Personal Data from Individuals in the EU and Switzerland
11.1
Privacy Shield Principles and Framework
CampusEd
Ireland transfers certain Personal Data to CampusEd, Inc. in the U.S. CampusEd,
Inc. (Education Integration Services, Inc.), complies with the EU-U.S. Privacy
Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by
the U.S. Department of Commerce regarding the collection, use, and retention of
Personal Data transferred from the EU member countries and Switzerland to the
United States. CampusEd has certified that it adheres to the Privacy Shield
Principles of Notice, Choice, Accountability for Onward Transfer, Security,
Data Integrity, and Purpose Limitation, Access, Recourse, Enforcement and
Liability. If there is any conflict between the policies in this Privacy Policy
and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
To learn more about the Privacy Shield program, and to view our certification,
please visit https://www.privacyshield.gov/
.
11.2
Principle of Onward Transfer
In the
context of an onward transfer of data to a third party, a Privacy Shield
organization has responsibility for the processing of Personal Data it receives
under the Privacy Shield and subsequently transfers to a third party acting as
an agent on its behalf. CampusEd shall remain liable under the Principles if
its agent processes such Personal Data in a manner inconsistent with the
Principles, unless CampusEd proves that it is not responsible for the event
giving rise to the damage.
12.
Independent Dispute Resolution For Individuals in the EU and Switzerland
In
compliance with the US-EU and Swiss-US Privacy Shield Principles, CampusEd
commits to resolve complaints about your privacy and our collection or use of
your Personal Data. EU and Swiss individuals with inquiries or complaints
regarding this Privacy Policy should first contact CampusEd at: CampusEd
Privacy Program, Director of Privacy, CampusEd, Inc., 6031 University Blvd.,
Suite 300, Ellicott City, Maryland 21043, USA or by emailing
support@campused.com
.
CampusEd
has further committed to refer unresolved privacy complaints under the EU-US
and Swiss-US Privacy Shield Principles to the BBB EU PRIVACY SHIELD, a
nonprofit alternative dispute resolution provider located in the United States
and operated by the Council of Better Business Bureaus. If you do not receive
timely acknowledgment of your complaint, or if your complaint is not
satisfactorily addressed, please visit
http://www.bbb.org/EU-privacy-shield/for-eu-consumers
for more
information and to file a complaint.
There may
be a possibility, under certain limited conditions, for EU and Swiss
individuals to invoke binding arbitration before the Privacy Shield Panel.
13. Do
Not Track Requests
We do not
respond to the browser “Do Not Track” (DNT) signal if enabled by the user in
their web browser. When we set or read cookies on non-CampusEd sites that have
integrated our job search and display features, we do so, for example, to
provide a personalized job search experience to users on those sites. We do not
share any information about your use of CampusEd with those third parties. When
third parties that we have integrated into CampusEd sites (as described in the
CampusEd Cookie Policy) set or read their own third-party cookies, they may or
may not respond to the DNT signal.
14.
Opting Out
If you no
longer want to receive marketing materials from us based upon your Personal
Data, going forward, you may opt out of receiving such marketing related
messages by sending an email to
support@campused.com
with “Opt Out” in the subject line. Please note that we may still
send other messages to you, such as administrative messages. We will comply
with your request as soon as reasonably practicable, and in accordance with
applicable laws.
15.
General Inquiries and Complaints
15.1
Contacting CampusEd
You may
contact CampusEd, Inc. at 6031 University Blvd., Suite 300, Ellicott City,
Maryland 21043, USA; or you may contact us at
support@campused.com
. If you would
like to contact CampusEd’s Data Protection Officer,
please send an email support@campused.com
.
15.2
Complaints
If you
believe your data protection rights have been infringed by CampusEd, you have
the right to complain to the appropriate data protection supervisory authority
in your jurisdiction. For example if you are in the EU, CampusEd’s
main establishment in the EU is CampusEd Ireland Operations Limited in Ireland,
and it is regulated by the Irish Data Protection Commission, in which case you
should consult this https://www.dataprotection.ie/docs/Making-a-Complaint-to-the-Data-Protection-Commissioner/r/18.htm for these purposes. If you are
in the EU or Switzerland and have a complaint with respect to transfers and
processing performed in accordance with EU-US and Swiss-US Privacy Shield
Principles then you may avail of independent dispute resolution, as detailed in
section 12 of this Privacy Policy.