CampusLogic Privacy Policy

Last Updated: March 23, 2022

INTRODUCTION

CampusLogic, Inc. (“CampusLogic,” “we,” and “our”) is committed to protecting the privacy of all individuals (“user” or “you”) who visit and use this website www.campuslogic.com or any other website that we own or control and which posts to this Privacy Policy (the “Site”) and/or the software applications (the “Applications”) provided by CampusLogic referred to collectively herein as the “Services.” This Privacy Policy (the “Privacy Policy”) describes how CampusLogic collects, uses, shares and safeguards personal information we collect when you use or interact with the Site or the Services. Please read the following information carefully to understand our views and practices regarding your personal information and how we will treat it. We also provide a supplementary privacy notice for users of the RaiseMe Service and a supplementary privacy notice for California residents.

This Privacy Policy does not apply to our processing of personal information provided to CampusLogic by our customers or otherwise collected by CampusLogic at the direction of customers (including, but not limited to, when we are acting as a “school official” on behalf of an educational institution), and which we process on behalf of our customers in our capacity as a service provider / processor. Our processing of that information is governed by our agreement with our customers.

If you registered to use the Services, you will have been asked to click to agree to provide this information in order to access our Services or otherwise view our content on the Site. If you do not agree to our use of your personal information in line with this Privacy Policy, please do not use our Services. By accessing and using our Site or by clicking “I accept” prior to your registration to the Services, you consent to the collection, use, and disclosure of your personal information by CampusLogic as described in this Privacy Policy.

We reserve the right to make changes to this Privacy Policy at any time, so we encourage you to review it frequently. If we change this Privacy Policy, we will post such changes to the Site and other places in the Applications we deem appropriate. The “Last Updated” legend above indicates when this Privacy Policy was last changed. If we make any material changes to the Privacy Policy, we will post the updated Privacy Policy on our Site prior to such changes taking effect. If required by law, we will also provide notification of material changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Applications.

1. COLLECTION OF INFORMATION

CampusLogic collects and retains personal information about you in the following ways:

Information You Give Us. This includes the personal information you voluntarily submitted to CampusLogic through the Site and/or Services, such as when you register to use our Services, including your name, postal address, email address, and other personal and unique information provided to CampusLogic based on your submissions and responses to questions asked of you throughout the Services.

You may also share personal information with us when you submit user generated content through our Services. Please note that any information you post or feedback you disclose to CampusLogic through the Site or on our Services will not be private or confidential once it is published on Site or through our Services. If you provide feedback to us, we may use and disclose such feedback in our Services or on our Site without any reference to you.

Information Automatically Collected. We automatically log information about you and your computer or mobile device when you access our Site and/or Services. Please refer to the sections on Tracking Technologies below.

2. USE OF INFORMATION

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use your personal information as follows:

• Service delivery, including:
  1. To fulfill a specific request by you.
  2. To operate, maintain, and improve our Site and Services.
  3. To manage your account, including to communicate with you regarding your account with our Services.
  4. To respond to your comments and questions and to provide customer service.
  5. To send information including technical notices, updates, security alerts, and support and administrative messages.
• Marketing and advertising. We may send you emails about upcoming events, promotions, and other news as permitted by law. You may opt out of our email marketing communications as described in the Opt-out of marketing communications section below. Please note that even if you opt out from receiving marketing emails, we may still send you non-marketing emails, which include emails about your account with us and in connection with your use of the Services.
• Compliance and protection. We may use your personal information as we believe necessary or appropriate (i) to comply with applicable laws; (ii) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (iii) to enforce our Privacy Policy; and (iv) to protect our rights, privacy, safety or property, and/or that of you or others.
• Research, Development and Services improvement. We may use your personal information for research and development purposes, including to analyze and improve the Services and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services.

3. DISCLOSURE OR SHARING OF INFORMATION

We may share your personal information as follows:

• Third Parties Designated by You. We may share your personal information with third parties where you have provided your consent to do so.
• Our Third-Party Service Providers. We may share your personal information with our third-party service providers who provide services such as information technology and related infrastructure, auditing, email delivery, and other similar services. These third parties are only permitted to use your personal information to the extent necessary to enable them to provide their services to CampusLogic.
• Corporate Restructuring. We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
• Other Disclosures. We may share personal information as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.

4. TRACKING TECHNOLOGIES

We may collect information using “cookies” and similar technologies. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience in the Services.

Cookies We Use. Our Services use the following types of cookies for the purposes set out below:

Type of cookie	Purpose
Essential Cookies	These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Services. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services. These cookies are only used for the duration of your session accessing the Services and are removed following completion of the session.
Functionality Cookies	These cookies allow us to remember choices you make when you use our Services, such as remembering your login details. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Services.
Analytics and Performance Cookies	These cookies are used to collect information about traffic to our Site and how users use our Services. The information gathered does not identify any individual visitor. The information is aggregated. It includes the number of visitors to the Site, the pages they visited on our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site/Application(s)/Services works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of [our Site/Application(s)/Services] by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB.

Other Technologies. We may also use other technologies, such as local storage technologies like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications, for analytics and marketing purposes.

Disabling Cookies. You can typically remove or reject cookies via your browser settings. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies, you may experience some inconvenience in your use of the Site or our Services.

Do Not Track Signals. Some browsers may be configured to send “Do Not Track” signals to the online services that you visit. We do not currently respond to “Do Not Track” or similar signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

5. THIRD PARTY WEBSITES

Our Site may contain links to third party websites and features. This Privacy Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. We recommend that you read their privacy policies before you submit any data to them.

If you elect to use the SponsoredScholar services, you will enter into an agreement with our payments partner, WePay, Inc., for the payments service and WePay's use of your data. Please review the WePay Privacy Policy (https://go.wepay.com/privacy-policy-us), which will apply to you.

6. SECURITY OF INFORMATION

We seek to use commercially reasonable organizational, technical and administrative measures to protect personal information within our organization. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Internet. Please keep this in mind when disclosing any personal information to us via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Applications, or third party websites. Additionally, you must keep your account password confidential and not disclose it publicly or to unauthorized individuals. If you have reason to believe that your interaction with us is no longer secure or your password was compromised or misused, please immediately notify us by contacting us at privacy@campuslogic.com.

We will only retain your personal information as long as reasonably required to provide you with the Services unless a longer retention period is required or permitted by applicable law.

7. PROCESSING OF PERSONAL INFORMATION IN THE UNITED STATES

CampusLogic is headquartered in the United States. Your personal information may be transferred, in accordance with this Privacy Policy, outside the country in which you reside, including to the United States, where data protection and privacy regulations may not offer the same level of protection as your home country or territory. We will take reasonable steps to protect your personal information in accordance with this Privacy Policy or as otherwise disclosed to you.

8. POLICY FOR CHILDREN

Neither our Site nor our Services are intended for use by children under 13 years of age. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us directly at privacy@campuslogic.com.

9. OPTIONS REGARDING YOUR INFORMATION

You have several choices regarding our use of your information, including the following:

1. Opt-out of marketing communications. You can opt out of receiving marketing-related communications by clicking on the unsubscribe link contained in the communications we send you or contacting us at privacy@campuslogic.com.
2. Opt Out of Push Notifications. If you opt-in to receive push notifications within the Applications, we may send push notifications or alerts to your mobile device from time to time. You can deactivate push notifications and alerts at any time by changing your device settings, changing the push notification settings within the Applications, or deleting the Applications.
3. Access. You may access the personal information we hold about you at any time via your account, or by contacting us at privacy@campuslogic.com.
4. Amend. You can contact us at privacy@campuslogic.com to update or correct any inaccuracies in the personal information that we hold about you.
5. Move. You can download your content stored in the Services at any time.
6. Erase. You can request that we erase the personal information that we hold about you. If you request that we erase your information, please note that your information may continue to reside on our backup systems.

We are committed to resolving any complaints about our collection or use of your personal information. If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your personal information, please contact us at privacy@campuslogic.com.

10. CONTACT INFORMATION

You may contact us by email at privacy@campuslogic.com or by sending a letter to the following mailing address:

• CampusLogic, Inc.
• 1340 S. Spectrum Blvd., Suite 200
• Chandler, AZ 85256
• United States
• Attn: Legal Department

ADDITIONAL PRIVACY POLICY PROVISIONS APPLICABLE TO USERS OF THE RAISEME SERVICE

1. ABOUT RAISEME

The RaiseMe service is a cloud platform and mobile application (collectively, “RaiseMe Service”) provided by CampusLogic that allows higher education institutions to offer micro-scholarships to student users that follow the relevant institution on the RaiseMe Service or to enrolled students for completing certain actions or desired behaviors.

RaiseMe partners with universities to offer students who are 13 years of age or over with scholarships for their achievements during high school and college.

These additional provisions are applicable to users of the RaiseMe Service and in addition to the CampusLogic Privacy Policy and all other privacy notices provided herein, and do not amend or replace the CampusLogic Privacy Policy and all other privacy notices provided herein.

2. COLLECTION OF INFORMATION YOU PROVIDE TO THE RAISEME SERVICE

Information you provide. Personal information you may provide to us through the RaiseMe Service or otherwise may include:

• Contact details, such as your name, email address, phone number.
• Account information, such as but not limited to a password or other information that helps us confirm that it is you accessing your account.
• Demographic or other information (such as your school, gender, age or birthday, and other information about your interests and preferences). You may also have the opportunity to create a profile, which may include personal information, such as photographs, information about your academic and work history, your interests and activities, your use of RaiseMe Service and other information. When you earn a Micro-Scholarship, you may be required to provide additional information directly to a college or university, such as proof of identity, proof of academic and work history (which may include high school transcripts, standardized test scores, or references from teachers or counselors), or proof of financial need (which may include completing a FAFSA or CSS profile, and providing other family income documentation), in order to claim the award.
• Verified third-party account credentials (for example, but not limited to your log-in credentials for Google Plus or other third party sites).

Third-party sources. We may receive personal information about you from third-party sources, as follows:

• Colleges and universities and other academic institutions that have awarded you Micro-Scholarships may share your application, enrollment and graduation information with us.
• High schools, colleges, universities or other educational partners may provide information about you to us. For example, we may receive from high school counselors your email address, so we can facilitate registration to the RaiseMe Service.
• If you provide your third-party account credentials to us or otherwise sign in to RaiseMe Service through a third party site or service, you understand some content and/or information in those accounts ("Third Party Account Information") may be transmitted into your account with us, and that Third Party Account Information transmitted to the RaiseMe Service is covered by this Privacy Policy; for example, if you log in to the RaiseMe Service through Google Plus, your Google Plus profile information will be populated into your profile on RaiseMe Service. The information we receive when you authenticate through a third-party service depends on the settings, permissions and privacy policy controlled by that third-party service. You should always check the privacy settings and notices in the relevant third-party services to understand what data may be disclosed to us or shared with the RaiseMe Service.

2. USE OF INFORMATION

We use your personal information to provide, maintain and support the RaiseMe Service and for the other purposes described in the CampusLogic Privacy Policy.

3. DISCLOSURE OR SHARING OF INFORMATION

Colleges: If you are a student, you may share your personal information with a College by taking certain actions on the RaiseMe Service, including, but not limited to, submitting your Micro-Scholarships for redemption, applying to specific programs and scholarships, or adding a College to your list of followed Colleges. By providing your email address or mobile phone number on the RaiseMe Service and following a College, you indicate interest in the College through RaiseMe, which authorizes the College to contact you directly via email or SMS (outside of the RaiseMe Service). You can always request directly to the College to opt out of any direct communication from them. Colleges are solely responsible for managing their messaging outside of the RaiseMe Service through email and/or SMS, as well as the opt-in or opt-out process for students to receive those messages.

Parents, Counselors, Guardians, and Advisors: The RaiseMe Service may permit Students to share access to their accounts with parents, guardians, school counselors, or other trusted advisors. If a Student permits such access, the permitted individuals will have access to the Student's account and personal information contained in the account. These additional users accessing the account agree to our Terms of Use by accessing the account. Counselors, Advisors and other school officials will be able to view certain personal information of other school officials at their institution, such as the school official’s name, title and email.

Non-Profit & Corporate Scholarship Administrators: If you apply for a Micro-Scholarship sponsored by a non-College third party, such as a non-profit or corporation, your profile information may be shared with a third-party scholarship administrator to select scholarship recipients. You authorize the third-party scholarship administrator to contact you directly to verify your profile information, including, but not necessarily limited to, obtaining copies of academic transcripts, proof of financial need if required, or any other documentation RaiseMe or the scholarship administrator requires to award the scholarship and disburse funds to you or your College.

Sponsors: If you follow a Sponsor, that Sponsor will receive access to your individual profile, including the personal information contained therein.

Affiliated Businesses and Third-Party Services: In certain situations, businesses or third-party websites we're affiliated with may sell or provide products or services to you through or in connection with the RaiseMe Service (either alone or jointly with us). We will share your personal information with that affiliated business only to the extent that it is related to such transaction or service. One such service may include the ability for you to automatically transmit Third Party Account Information to your RaiseMe profile or to automatically transmit information in your RaiseMe profile to your third-party account; for example, we may permit you to "like" content within the RaiseMe Service or "share" content to other web sites, such as Facebook or Twitter. If you choose to "like" or "share" content or to otherwise post information from or via the RaiseMe Service to a third-party website, feature, or application, that information may be publicly displayed, and the third party website may have access to information about you and your use of our RaiseMe Service. In addition, certain third-party partners may use cookies, web beacons, and other storage technologies to collect or receive information from you via our website and elsewhere on the Internet and may use that information to provide measurement services, to target ads, or generally to improve the nature or quality of the services that they provide. We have no control over the policies and practices of third-party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to or involving an affiliated website or business, please review all such businesses' or websites' policies.

Privacy Notice for California Residents

Effective Date: July 1, 2020

This Privacy Notice for California Residents (“Notice”) supplements the information contained in the Privacy Policy of CampusLogic Inc. (“CampusLogic”) and applies to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

This Notice does not apply to the personal information of individuals with whom CampusLogic engages in the individuals’ capacity as representatives of businesses that may provide services to CampusLogic, or to which CampusLogic may provide services.

1. Information We Collect

From Consumers. Our Services (as defined in the CampusLogic Privacy Policy) may collect personal information as defined by the CCPA (as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household) (“personal information”). This personal information may be collected directly from you on the Site (as defined in the CampusLogic Privacy Policy) or through the Services, or indirectly from you, for example by observing your actions in the Services or on the Site.

From Covered Businesses. Our Services may also collect such personal information from consumers indirectly from a for-profit educational institution, college, or university that may be a covered business under the CCPA. In such event, CampusLogic is deemed a service provider that processes personal information on behalf of such covered business for the purpose of providing access to the Services as ordered and subscribed to by the covered business. Such processing activities are governed by the contract between CampusLogic and such covered business and the privacy policies or notices of such covered business, and not by this Notice.

We have collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	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.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	NO
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

Personal information does not include:

1. Publicly available information from government records.
2. De-identified or aggregated consumer information.
3. Information excluded from the scope of the CCPA, including: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

2. Use and Sharing of Personal Information

You can read about how we use personal information in the “Use of Information” section of the CampusLogic Privacy Policy. We may share personal information as described in the “Disclosure or Sharing of Information” section of the CampusLogic Privacy Policy

3. Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, CampusLogic may have disclosed the following categories of personal information for a business purpose:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category C: Protected classification characteristics under California or federal law.
• Category J: Non-public education information.

CampusLogic may disclose your personal information for a business purpose to the following categories of third parties:

1. Third Parties.
2. Service providers.
3. Corporate Restructuring.
4. Other disclosures (legal purposes).

4. Your Rights and Choices

The CCPA provides California residents the following rights.

Information

This Notice describes how we use and share your personal information through the Services, including during the past 12 months. This Notice describes:

• The sources through which we collect California residents’ personal information and the types of personal information collected in the “Information We Collect” section above.
• The purposes for which we use and share this information in the “Use and Sharing of Personal Information” section above.

Access.

You can request a copy of the personal information that we maintain about you. The CCPA limits this right. For example, companies may not provide users in response to access requests certain sensitive information and other consumers’ personal information and may exclude information that would compromise the confidentiality of trade secrets.

Deletion.

You have the right to request that CampusLogic delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your Rights.

To exercise your rights described above, please submit a verifiable consumer request to us by either: Calling us at 602.643.1300, or emailing privacy@campuslogic.com.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

The verifiable consumer request must:

1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

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. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response electronically.

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.

Personal Information Sales Opt-Out and Opt-In Rights

CampusLogic does not sell personal information of consumers.

Non-Discrimination.

We will not discriminate against you for exercising any of your CCPA rights.

Other California Privacy Rights.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. CampusLogic does not disclose personal information to third parties for their direct marketing purposes. For more information, please send an email to privacy@campuslogic.com.