Your privacy is important to us and maintaining your trust is our priority. The OnCampusNation.com website is owned and operated by OnCampusNation, Inc. (“OnCampusNation,” “we,” “our,” or “us“). OnCampusNation respects your privacy and is committed to protecting it through our compliance with this California Privacy Notice (“Privacy Notice”).
1. Types of Users
The personal information we collect depends on how you use or interact with our Platform. Table 1 below indicates the general types of consumer users of our Platform (collectively, “Users”).
2. Types of Information We Collect
A. Personal Information Collected
Our Platform collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). Table 2 below identifies the categories of personal information that OnCampusNation has collected from consumers in the preceding twelve (12) months, based on the type of User.
NOTE: OnCampusNation has not collected any of the following categories of personal information from consumers within the last twelve (12) months:
Protected classification characteristics under California or federal law
Biometric information (such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data)
Sensory data (such as audio, electronic, visual, thermal, olfactory, or similar information)
Non-public education information, per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) (such as education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Other sensitive personal information, as defined in the CCPA, that is not otherwise identified above (for example, in the preceding twelve (12) months, we have not collected precise geolocation, genetic data, or personal information concerning a consumer’s health, sex life, or sexual orientation).
B. Non-Personal Information Collected
OnCampusNation collects, uses and shares de-identified and/or aggregated consumer information, which is not considered personal information. Deidentified or aggregated data may be derived from your personal information, but is not considered personal information under CCPA, since it does not directly or indirectly reveal your identity. For example, we may aggregate your Internet or other similar network activity to calculate the percentage of users accessing a specific website feature.
C. Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
Directly from you. For example, when you fill in forms, sign up for a free trial or paid subscription, create an account, or correspond with us by post, phone, e-mail or otherwise.
Indirectly from you. For example, through automated technologies or your interactions with us, including from observing your actions when you use our Platform.
From Your Company. If your company is a Customer, we may receive personal information about you from your company for purposes of setting you up with a User account on our Services, or as otherwise required by your company for OnCampusNation to provide the Services.
Third Parties. We may receive personal information about you from various third parties, such as data analytics providers, data brokers (for business-related data), advertising networks, service providers, or other third parties that you direct to share information with us.
In our capacity as a service provider (see Section 7 below).
3. Our Business or Commercial Purposes for Collecting, Selling, or Sharing Personal Information
A. Purposes for Collecting or Using Your Personal Information
To fulfill or meet the reason for which the personal information is provided. For example, if you provide your personal information to create an account, we will use that information to create your account.
To create, maintain, manage, customize, and/or secure your account with us.
To communicate with you about your account or our Platform, and to manage our relationship with you.
To provide you with support and to respond to your inquiries, including investigating and addressing your concerns and monitor and improve our responses.
To send you marketing communications (where you have asked us to or where permitted, and you have not otherwise opted out).
To send you newsletters where you have indicated an interest or shown an interest based on your preferences as shown by your activity on the Website and/or your profile.
To maintain certain of your information on a suppression list, if you’ve indicated to us that you don’t want to be communicated in a particular way.
To manage any promotions or competitions you entered.
To seek your feedback via a survey that gathers your sentiments on various topics or aspects of our Platform (where you have not otherwise opted out of receiving such surveys).
To personalize your Platform experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email.
To enable our Platform to function properly (ensure proper display of content), create and remember your account login details, and for interface personalization, such as language, or any user-interface customization.
To provide, support, personalize, and develop our Platform.
To process your requests, purchases, transactions, and payments, and prevent transactional fraud.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing or collections, or manage payment disputes or issues with the Platform.
To help maintain the safety, security, and integrity of our Platform, databases and other technology assets, and business.
To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
For testing, research, analysis, and product development, including to collect statistics and develop and improve our Platform.
For debugging to identify and repair errors that impair existing intended functionality of our Platform.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
In connection with or during negotiations of any proposed or actual financing, merger, purchase, sale, sale or transfer of some or all of our assets or stock, joint venture, or any other type of financing, acquisition or business combination of our company, or all or any portion of our assets, or transfer of all or a portion of our business to another company, including without limitation in the event of a divestiture, restructuring, reorganization, dissolution or other event, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by OnCampusNation is among the assets transferred.
OnCampusNation may collect or use your sensitive personal information as necessary to perform the services or provide the goods reasonably expected, or as otherwise permitted by the CCPA. Specifically, OnCampusNation collects or uses your sensitive personal information for the following purposes:
For Customers, where we collect an account log-in and password, this information is used to permit you to access your OnCampusNation.com account, provide you with access to the Platform, authenticate you as a user, and for other security-related purposes.
OnCampusNation will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
B. Purposes for Selling or Sharing Your Personal Information
OnCampusNation may sell or share your personal information for the following business or commercial purposes:
To deliver targeted offers and advertisements about the Platform or other OnCampusNation services through third-party sites, including third-party segment creation and frequency capping.
Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, measuring ad performance, conducting ad fraud detection, recording on ad viewability, and auditing compliance.
OnCampusNation does not sell or share any sensitive personal information, and it does not have actual knowledge that it sells or shares personal information from individuals under 16 years of age.
4. How We Disclose Your Personal Information
A. Disclosures of Personal Information for a Business Purpose
In addition, OnCampusNation may disclose any or all of the personal information identified in the categories above to the following categories of third parties for a business purpose, depending on how you interact with our Platform and/or where OnCampusNation has an obligation to make such disclosure:
Social networks, where you interact with such parties directly
Third party partners that are integrated into our Platform, where you interact with such partners directly
Government entities, where required by law or in order to comply with our legal or regulatory obligations
Other third parties, where required by law or in order to protect our rights, or the rights of our customers or others
Third parties, in connection with a merger, sale, or asset transfer.
Third parties, where you have expressly consented to the disclosure your personal information
OnCampusNation does not use or disclose sensitive personal information, except as necessary to perform the services (as detailed further in this Privacy Notice).
B. Sale or Sharing of Personal Information
Your privacy is our priority, and we do not monetize your personal information by selling it to third parties.
After you visit our Website, you may receive targeted advertisements about the Platform or Services when you visit other websites (i.e., social media sites, search engines or other websites that are unrelated to OnCampusNation or OnCampusNation.com) (collectively, “Other Websites”). This happens because we use third-party vendors to provide you with information about our Services based upon your interactions with our Website. We also may place third-party cookies and other tracking technologies on our Website to track your interactions with OnCampusNation ads placed on Other Websites.
When personal information is disclosed by OnCampusNation in the manner described above, it may constitute a “sale” or “sharing” of personal information under the CCPA.
Pursuant to the CCPA, in the preceding twelve (12) months, we have sold or shared the following categories of personal information for the purpose of showing you ads about our Services:
Category A: Identifiers
Category D: Internet or other similar network activity
Category E: Geolocation data
In this limited capacity, we may sell or share each of the categories of personal information listed above with the following categories of third parties:
Third-party advertising partners or advertising networks
The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
OnCampusNation does not sell or share any of your sensitive personal information, and does not sell or share the personal information of consumers under 16 years of age.
5. Your Consumer Rights
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how you can exercise them. These rights are not absolute and certain exceptions apply under the CCPA, such as when you provide personal information in your capacity an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, or government agency in the context of OnCampusNation providing a service to that company, partnership, sole proprietorship, non-profit, or government agency.
If you are a California resident, and the CCPA does not recognize an exception that applies to you or your personal information, you will have the rights identified in Table 4 below.
6. How to Exercise Your Consumer Rights
We have designed a number of tools to help give you more control over your personal information. To exercise a CCPA consumer right as described above, you can use one of the self-serve tools described below, or otherwise submit a verifiable consumer request to us by email.
A. Correcting Inaccurate Information
For Customer Accounts: If you are a Customer with an account, and would like to correct any inaccurate personal information we hold about you, you may log in to your password-protected account, and navigate to the “My Account” tab (to update your name, email, phone number or password), “Manage User” tab (to update your name, email, or phone number) or the “Edit Account” tab (to add or change your account plan, Stripe customer token, business address and location).
Send Us an Email with Your Request: For personal information that cannot be corrected through the self-serve tools noted above, you may send an email to email@example.com (with a copy to support@OnCampusNation.com), and specify that your request relates to the “OnCampusNation.com website”. To submit a verifiable consumer request via email, you must email us from the email address that is associated with your User account (if you have one) or from the email address that was originally provided to us in the context of OnCampusNation collecting your personal information, and identify what personal information we maintain that is inaccurate and which you are unable to correct.
B. Accessing or Deleting Your Personal Information
You may send an email to firstname.lastname@example.org (with a copy to support@OnCampusNation.com), and specify that your request relates to the “OnCampusNation.com website”. To submit a verifiable consumer request via email, you must email us from the email address that is associated with your User account (if you have one) or from the email address that was originally provided to us in the context of OnCampusNation collecting your personal information. You may be asked to provide identifying information that enables us to verify you with information in our system. Once you submit your verifiable consumer request, we will verify your identity by matching the information you provided us with information in our systems.
C. Opting Out of the Sale or Sharing of Your Personal Information
For more information, or to submit an opt-out request, you (or your authorized representative) may visit our Notice of Right to Opt-Out page or email your request to email@example.com (with a copy to support@OnCampusNation.com), and specify that your request relates to the “OnCampusNation.com website”. You do not need to create an account with us to exercise your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request.
You may also use an opt-out preference signal, such as the Global Privacy Control (GPC), to opt-out of the sale and sharing of your personal information in accordance with the CPRA. If you use the GPC, your request to opt-out of the sale and sharing will be linked to your browser identifier only. It will not be linked to your email address. If you would like us to make the connection between your browser and your email address, and you have not yet opted out of sale or sharing your personal information, please visit the Notice of Right to Opt Out page linked above.
D. Making a Verifiable Consumer Request
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Using an Authorized Agent: If you use an authorized agent to submit a consumer request the authorized agent must provide documentation or other proof indicating that they are authorized to act on your behalf. For requests to correct, access or delete, we may require you to verify your identity directly with us (for example, by emailing us directly from the email address associated with your Customer account), and directly confirm with us that you provided the authorized agent permission to submit the request.
If you are an authorized agent, you may make a request by emailing firstname.lastname@example.org (with a copy to support@OnCampusNation.com), specifying that your request relates to the “OnCampusNation.com website”, and providing documentation or other proof indicating that you are authorized by the consumer to act on their behalf. The agent must provide documentation necessary (as determined in OnCampusNation’s discretion) to verify the agent has authority to act on the consumer’s behalf in relation to CCPA requests.
Limitations on CCPA Requests: You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Metrics: Metrics related to CCPA requests received during the previous calendar year are available here.
E. Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing (email suffices). Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
For data access requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
7. OnCampusNation as a Service Provider
In certain instances, Customers hire OnCampusNation to provide the Services on behalf of the Customer. In such a case, we process personal information under the direction of that Customer as a service provider, and we have no direct relationship with the individuals (consumers) whose personal information we process.
Where OnCampusNation acts as a service provider, it will be subject to a separate JBIO Master Services Agreement executed or agreed to by the Customer, which expressly incorporates the Privacy and Security Addendum (“Privacy Addendum”). The Privacy Addendum requires OnCampusNation to collect, retain, use, disclose, and/or otherwise process personal information solely as a service provider
Where OnCampusNation collects your personal information in the capacity of a service provider, and you seek access, or want to access, correct, amend, or delete your personal information, or have another request, we will provide you with the Customer’s contact information, so you can contact them directly. In rare instances, however, circumstances may necessitate OnCampusNation assisting you with your question or request.
8. Retention of Personal Information
Different retention periods apply for different types and categories of personal information. Table 5 below identifies the criteria used to determine the length of time OnCampusNation intends to retain each category of personal information. Once you request that we delete your personal information, we will do so except where we are otherwise permitted or required to retain that information in accordance with applicable laws and regulations.
9. Changes to this California Privacy Notice
We reserve the right to change this Privacy Notice at any time. If we propose to make any material changes, we will notify you by posting a notice on the Website or by issuing an email to the email address listed by registered users prior to the changes becoming effective, and will update the Privacy Notice’s effective date. You acknowledge that it is your responsibility to maintain a valid email address as a registered user, and to review the Website and this Privacy Notice periodically in order to be aware of any modifications. If you object to any changes to the revised Privacy Notice, you can stop using our Platform and close your account with us. However, if you continue to use any part of our Platform after we publish a new or updated Privacy Notice, you acknowledge that such continued use means that the treatment of your personal information will be subject to the new or updated Privacy Notice.
10. Contact Information
If you have any questions or comments about this Privacy Notice, the ways in which OnCampusNation collects and uses your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us by using the communication means described below