EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
We are committed to upholding the Privacy Shield Principles.
OnCampusNation participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. OnCampusNation is committed to subjecting all Personal Data received from European Union (EU) member countries, Switzerland and the United Kingdom, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list.
OnCampusNation is responsible for the processing of Personal Data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. OnCampusNation complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, Switzerland and the United Kingdom, including the onward transfer liability provisions.
With respect to Personal Data received or transferred pursuant to the Privacy Shield Frameworks, OnCampusNation is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, OnCampusNation may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Click on the links below to navigate to the applicable section:
Who We Are
Data We Collect About You
How Data Is Collected
How We Use Your Data
Who We Share Your Data With
Where Your Data is Transferred
How Long Your Data Will Be Kept
Your Data Subject Access Rights
California Privacy Rights
Cookies and Tracking Technologies
Links to Third Party Websites and Social Media Features
Questions or Complaints
Minors & Children
How to Contact Us
1. WHO WE ARE
The Website is owned and operated by OnCampusNation, which provides an online employment marketplace that connects employers to job seekers.
604 Arizona Avenue, Santa Monica, California 90401, USA
Delaware corporation (File Number 4829724)
Pursuant to Article 27 of European Union’s (“EU”) General Data Protection Regulation (“GDPR”), we have appointed a representative in Ireland to act as our GDPR representative in the EU, where required (“EU GDPR Representative”). In addition, pursuant to Article 27 of the United Kingdom’s (“U.K.”) General Data Protection Regulation (“U.K. GDPR”), we have appointed a representative in the U.K. to act as our U.K. GDPR representative, where required (“U.K. GDPR Representative”). You can contact our EU GDPR Representative or our U.K. GDPR Representative by sending an email or by writing to the applicable GDPR Representative identified below:
For more information on the transfer of Personal Data outside the EEA, Switzerland, or the U.K, please see Section 7 below.
2. KEY TERMS
3. DATA WE COLLECT ABOUT YOU
A. Personal Data
As permitted by applicable law in the country from which you access our Website and use our services, we may collect, use, store and transfer different kinds of Personal Data about you. We have grouped these into the following categories of Personal Data:
“Identity Data” such as first name, last name, and username or similar identifier.
“Contact Data” such as billing address, email address, social media address or handle, telephone number, and other contact information you may provide.
“Financial Data” such as payment card details or financial account information. However, please note that payment methods (e.g., credit or debit card number and/or bank account details) are not collected by us directly, but by our third-party payment service providers.
“Business Data” such as your company name, business address, description, logo, favicon, and company websites.
“Transaction Data” such as details about payments to and from you, and details regarding the services that you have subscribed to in relation to this Website.
“Technical Data” such as Device IDs, your login data, access dates and times, browser type and version, device information, cookie data, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.
“Profile Data” such as your username and password, orders made by you, preferences, feedback and survey responses.
“Usage Data” such as information about how you use our Website, products and services.
“Marketing and Communications Data” such as your preferences in receiving marketing from us and our third-parties and your communication preferences.
B. Non-Personal Data
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Data but is not considered Personal Data since it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
C. If You Fail to Provide Personal Data Where Required to Provide Services to You
Where we need to collect Personal Data by law, or under the terms of a contract we have with you, or a prospective contract, and you fail to provide that Personal Data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel the service you have with us (or requested from us), and you accept that as a condition of service.
D. Data That You Should Not Provide to Us
We do not require any Special Categories of Personal Data about you. Accordingly, please do not provide this type of personal data to us.
4. HOW DATA IS COLLECTED
We use different methods to collect Personal Data from and about you including, for example:
A. Direct Interaction
You may give us your identity, contact, billing and other information by filling in forms on the Website or by corresponding with us by post, phone, e-mail or otherwise. This includes Personal Data you provide when you:
sign-up for a free trial;
sign-up for a paid subscription;
create an account on our Website;
request information to be sent to you;
give us some feedback; or
otherwise submit Personal Data to us.
B. Automated Technologies or Interactions
As you interact with our Website, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this Personal Data and Non-Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data and Usage Data about you if you visit other websites employing our cookies and other Tracking Technologies (defined below). For more information regarding our use of Tracking Technologies, please refer to “Cookies and Similar Technologies” below.
C. Third Parties
We may receive Personal Data in the form of Technical Data and Usage Data about you from various third-parties, such as analytics providers or advertising networks.
D. OnCampusNation as a Service Provider (Data Processor)
OnCampusNation acknowledges that you have the right to access your personal information. In certain instances, our OnCampusNation.com clients contract with OnCampusNation to provide services on behalf of the client. In such case, we process Personal Data under the direction of that client (the data controller) and have no direct relationship with the individuals (data subjects) whose Personal Data we process in providing the OnCampusNation.com services.
Where OnCampusNation processes your Personal Data in the capacity of a service provider (data processor) (e.g., if you are a customer of such a OnCampusNation client) and you seek access, or want to correct, amend, or delete your Personal Data, or have another request, we will provide you with the data controller’s contact information, so you can contact them directly. In rare instances, however, circumstances may necessitate OnCampusNation assisting you with your question or request. We may transfer Personal Data to companies that help us provide our services (our subprocessors). Transfers to subsequent third parties are covered by our service agreements with our clients.
We will retain Personal Data that we process on behalf of our clients for as long as needed to provide services to our client. OnCampusNation will retain this Personal Data as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and in accordance with our internal record keeping policies.
5. HOW WE USE YOUR DATA
A. Use of Non-Personal Data
B. Use of Personal Data
We will only use your Personal Data as permitted by applicable law (i.e., when we have a business or commercial reason to use your Personal Data). For example, when processing Personal Data from data subjects in the EU, Switzerland and the United Kingdom (collectively, “European Data Subjects”), we will process your Personal Data for the following purposes:
Where we need to perform the contract we are about to enter into with you or have entered into with you
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
Where we need to comply with a legal or regulatory obligation
Where you have given us your consent
C. Purposes for Which We Use Your Personal Data
In the table below, we have described (i) in what context your Personal Data was collected, i.e., what activity you were involved in when we collected or used your Personal Data; (ii) the types of Personal Data that we hold about you; (iii) how and why we use your Personal Data; and (iv) what our legal basis is for using your Personal Data. We will amend this table as required.
For European Data Subjects, we have also identified in the last column our lawful basis where appropriate. We have also provided you with an explanation of some of the terms we use in this table:
‘Legitimate Interest’ means our interest in conducting and managing our business, to enable us to give you the best experience when using the Website, products, and services. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
‘Performance of Contract’ means processing your Personal Data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
‘Comply with a legal or regulatory obligation’ means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.
‘Consent’ means that you consent to our use of your Personal Data for one or more specific purposes. Where we rely on your consent to use your Personal Data, you have the right to withdraw that consent at any time. You can do this by contacting us at email@example.com. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
6. WHO WE SHARE YOUR DATA WITH
A. Personal Data
We may share Personal Data with the following parties:
Companies within our corporate family that comprise the OnCampusNation Group. Access to your Personal Data will be controlled and only granted where necessary to provide our services to you and/or to allow us to perform any necessary or legitimate functions.
Service providers that we use to support our business and/or help provide our services to you, including, but not limited to, third-parties that host our Website, assist us to verify your identity, perform website and platform maintenance, risk assessments, and security, perform data and web analytics, provide databases, IT services, customer service, payment platforms and credit card processing, communication services, and email services
Professional advisers such as lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance, financial, auditing, and accounting services to us so we can operate our business
Taxing authorities, such as the Internal Revenue Service and other authorities acting as processors based in the United States, the United Kingdom and other applicable countries, who require reporting of processing activities in certain circumstances
Fraud prevention and identity verification services where we believe that disclosure is necessary or appropriate to protect the rights, property, or safety of OnCampusNation, our customers, or others. This includes exchanging information with third-parties for the purposes of fraud detection and prevention, and credit risk reduction
Third parties, where you have expressly consented to the disclosure of your Personal Data
Law enforcement agencies, courts, supervisory authorities, regulatory bodies and certain other third-parties, to the extent that we are permitted or required to do so by law, or in order to comply with our legal and regulatory obligations, or in the interests of national security, or to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity
For any other purpose disclosed by us when you provide the information to us on the Website, or otherwise with your express consent.
B. Non-Personal Data
7. WHERE YOUR DATA IS TRANSFERRED
OnCampusNation, Inc. is headquartered in the United States of America (USA).
The information that you provide or that we collect as a result of your interaction with the Website and/or your use of our services on the Website is transferred to the USA and/or to another country where we have a subsidiary or where we have engaged service providers (data processors or subprocessors). Some countries that are not located within the EU or U.K. may be recognized by the European Commission as providing an adequate level of data protection. For transfers from the EU or U.K. to countries not considered as adequate by the European Commission, we have put in place measures, including by ensuring that the recipient is bound by EU Standard Contractual Clauses, to protect your Personal Data, which can be found at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en. When we transfer Personal Data from the EU, U.K, or Switzerland to the USA, we also adhere to the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks (“Privacy Shield”), and the Privacy Shield Principles, as described in our Privacy Shield certification, which you can find at https://www.privacyshield.gov/participant?id=a2zt0000000TNnuAAG&status=Active.
8. HOW LONG YOUR DATA WILL BE KEPT
Different retention periods apply for different types of Personal Data and in determining the appropriate retention period, we consider several criteria, including, but not limited to, the purpose for which we hold your Personal Data; our legal, accounting, reporting and/or regulatory obligations in relation to that Personal Data (e.g., financial or tax reporting obligations); whether our relationship with you is ongoing (e.g., where you use more than one of our products and/or services); any specific request you may have made in relation to the deletion of your Personal Data; or where we have a legitimate interest in relation to the management of our own rights (e.g., the defense of any claims). In some circumstances, we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Once you no longer have a relationship with us, we will retain, or securely destroy or destroy, your Personal Data subject to the foregoing and in accordance with applicable laws and regulations. If you request to receive no further contact from us, we will keep some basic information about you on our suppression list in order to avoid sending you unwanted materials in the future.
9. YOUR DATA SUBJECT ACCESS RIGHTS
You may have different privacy rights under applicable laws depending on the country you are in when you visit or access our Website.
For European Data Subjects, you have the following rights with respect to your Personal Data:
For data subjects outside the EEA, Switzerland, and U.K.: Depending on applicable law, you may have the following rights with respect to your Personal Data:
If you have any complaints about how OnCampusNation handles Personal Data, please send an email to firstname.lastname@example.org, and identify that your request relates to the OnCampusNation.com Website. We welcome the opportunity to help you with any concern or questions you may have about the use of our services, and we will respond to your request within a reasonable timeframe.
For residents located in Nevada: Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to email@example.com and identify that the request relates to the OnCampusNation.com Website. However, please know OnCampusNation does not currently sell data triggering the opt-out requirements under Nevada Revised Statutes Chapter 603A.
For residents located in Virginia: If required by Virginia’s Consumer Data Protection Act, Va. Code Ann. § 59.1-571 et seq., and its implementing regulations (collectively, the “CDPA”), Virginia residents also have the right to: (i) opt out of processing of Personal Data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects (if such profiling occurs); and (ii) appeal any decision by OnCampusNation not to take an action relating to your CDPA rights by sending an email to firstname.lastname@example.org, and identifying that your request relates to the OnCampusNation.com Website.
A. Method for Requesting Information Pursuant to Your Rights
If you would like to exercise any of the data subject access rights in the table above (each, a “Data Subject Request”), please send an email to email@example.com with your specific request and identify that your request relates to the OnCampusNation.com Website. We will respond to your request within a reasonable timeframe.
B. No Fee Usually Required
You will not usually be required to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances and, in such case, we will notify you within a reasonable timeframe regarding our reasons for refusing to act on your request.
C. What We May Need from You
Once we receive your Data Subject Request, we may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.
If we are not clear as to what you are requesting, we may also need to contact you for clarification so we can more fully respond to your request.
If we cannot locate any records about you, we may also ask you for additional information to assist us in locating records, if they exist.
D. Time Limit to Respond
We try to respond to all legitimate requests within the timeframes required under applicable law. Occasionally it may take us longer than the time period required under applicable law if your request is particularly complex or you have made a number of requests. In this case, we will notify you as to the reason for the delay.
10. CALIFORNIA PRIVACY RIGHTS
California residents have the right to request certain information regarding our disclosure of personal information (as defined by the California Shine the Light Act) to third parties for their direct marketing purposes unless we provide them with an ability to exercise choice regarding such disclosures. We comply with this law by providing California residents with the ability to opt-out of, or prospectively withdraw their consent, if they have previously opted-in to, the disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, to receive confirmation of how we comply with this law, or to make a request or to opt out at any time, please contact us firstname.lastname@example.org or mail us at the address provided in Section 18 below. Any request must include “California Privacy Rights Request” in the first line of the description and must include the requestor’s name, street address, city, state, and ZIP code.
If you are a visitor or user who resides in the State of California, you can view our “California Privacy Notice” for OnCampusNation.com here.
We may use your Personal Data to send you information about the services provided by the OnCampusNation Group; provided, however that we will obtain consent to do so from European Data Subjects, or where otherwise required in accordance with applicable law. You may unsubscribe from our marketing emails by clicking “Unsubscribe” in any promotional e-mail communications we send you. As permitted by applicable law, you cannot opt-out of non-marketing, services-related notices.
12. COOKIES & TRACKING TECHNOLOGIES
If you are accessing the Website from a location outside the EEA or U.K., you understand that we apply U.S. law and the U.S. advertising industry self-regulatory program to Tracking Technologies associated with the Website.
13. DATA SECURITY
We use appropriate technical and organizational measures to protect Personal Data we process about you.
However, no transmission of information via the Internet or wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Data, you acknowledge that there are security and privacy limitations of the Internet which are beyond our control and accordingly, the security, integrity and privacy of data exchanged between you and us through the Website cannot be guaranteed.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
The safety and security of your Personal Data also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your login or account credentials with anyone and keep your account information secure. We urge you to be careful about giving out information in public areas of the Website like message boards, where information will be available to other users of the Website. If you believe that your access credentials or Personal Data have been compromised, please contact us immediately.
14. LINKS TO THIRD PARTY WEBSITES AND SOCIAL MEDIA FEATURES
Our Website may, from time to time, contain links to third-party services such as websites, locations, platforms, applications or services operated by third parties. If you follow a link to or otherwise access any of these third-party services, these third-party services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personal Data from you. Please note that these third-party services have their own privacy policies and we do not accept any responsibility or liability for these parties’ policies or practices. Please check these policies before you share any Personal Data with these third-party services.
The Website may include tools provided by us or third-party services that enable you to send a message to another person. If you use any such tools, please ensure that you only send messages to persons to whom you have permission to send messages. Absent the recipient’s consent, we will only use their Personal Data that you provide us to facilitate such messages.
15. QUESTIONS OR COMPLAINTS
If you have a complaint, or if you have questions or requests regarding your Personal Data, please email us at email@example.com, and specify the country in which you are located and identify that the request relates to the OnCampusNation.com Website. We welcome the opportunity to help you with any concern or questions you have about the use of our Website or services.
If we are not able to address your concern and if you are a European Data Subject, you have the right to lodge a complaint with the Data Protection Authority where you are located or where the issue took place. For contact details of your local Data Protection Authority, please see www.ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. Contact information for the Information Commissioner’s Office (ICO), which is the supervisory authority in the U.K. can be found at https://ico.org.uk/make-a-complaint.
17. MINORS & CHILDREN
Our services and the Website are not intended for use by persons under the age of 18 years. OnCampusNation does not knowingly collect or solicit Personal Data from anyone under the age of 13 or knowingly allow such persons to register to use our Website. In the event that we learn that we have collected Personal Data of a child under the age of 13, we will delete that data to the extent required by applicable law as quickly as possible. If you believe that we might have any Personal Data from or about a child under 13, please contact us at firstname.lastname@example.org.
18. HOW TO CONTACT US
Data Privacy Questions or Requests. If you have any questions regarding our Personal Data practices, or would like to unsubscribe, please contact us by using the communication means described below and identify that the request relates to the OnCampusNation.com Website.
Technical Support or Customer Service Questions or Requests Wherever you are located, if you have any questions about your account, and/or technical or other customer support questions about your use of our services, please contact our Customer Service team by using one of the communication means described below.
Email Address: email@example.com
Mailing Address: See Below