1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that your school or you provide to us such as email addresses, ID number, name, and passwords for non-SSO authentication.
We collect personal information that you voluntarily provide to us when you contact us, register on the Sites, including the choices you make and the products and features you use. The personal information that we collect depends on the context of your interactions with us and the Sites and may include the following:
Contact data. We collect your email address and your ID number if you make an unauthenticated deposit. We collect your photo if your school uses our Photo Upload package, and you use our page to submit your photo.
Credentials. We collect passwords and similar security information used for account authentication and account access.
Location. We do not store location data of any kind. Location data is requested from the Atrium Campus Connect app to provide real-time location assistance to all applicable features in the app. For example the location of the phone compared to the distance to points of interest on campus.
Payment data. We do not collect or store any payment information of any kind. All payment data is collected and stored by CyberSource, our payment gateway, and you should review its privacy policies and contact them directly to respond to your questions.
Information automatically collected
In Short: Some information such as usage information, IP address, device model, inferred geolocation information, operating system, and other unique device identifiers may be collected automatically when you visit our Sites. We also receive your school ID number, name, and recent ID card system transaction history periodically from your school.
We automatically collect certain information when you visit, use, or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include your IP address. This information is primarily needed to maintain the security and operation of our Sites, and for our reporting purposes.
We also receive your school ID number, name, and the recent transaction history from your school ID card system in a nightly process. This information is overwritten nightly.
Like many businesses, we collect this information through cookies and similar technologies. Please see additional information regarding cookies below.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We and our third-party service providers collect and use your information for purposes based on legitimate business interests, the fulfillment of our contract with you and your school, compliance with our legal obligations, and/or your consent.
- you expressly authorize us to do so,
- it is necessary to allow our service providers, agents, or other third parties to provide products or services for or to us,
- it is necessary to provide the Sites or services,
- we are sending you other information that may be useful to you,
- subject to applicable contractual or legal restrictions, it is disclosed to entities that perform marketing services on our behalf or to other entities with whom we have joint marketing agreements,
- it is necessary to protect the confidentiality or security of your records,
- it is necessary in connection with other business purposes including, without limitation, verifying your identity, age, and/or payment details, investigating complaints about the Sites, risk assessment, security, fraud and crime prevention/detection, monitoring, research and analysis, marketing, customer purchasing preferences and trends and dispute resolution,
- it is necessary to comply with law enforcement, a governmental mandate, or other legal requirement, if appropriate, for your protection or in connection with an investigation or prosecution of possible unlawful activity,
- subject to applicable contractual or legal restrictions, it is necessary in connection with a sale of all or substantially all the assets of us or the merger of us into another entity or any consolidation, share exchange, combination, reorganization, or like transaction in which we are not the survivor, or
- it is otherwise necessary for us to disclose it as required or permitted by law.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We share and disclose your information in the following situations:
Business obligations. We may share information, which may include personal information, with trusted business parties to help deliver services, perform statistical analysis, send you communication, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to the Sites, and they are required to maintain the confidentiality of your information.
Compliance with laws. We may disclose your information where we are legally required to do so to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as a response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements) or are otherwise legally required to disclose information.
Vital interests and legal rights. We may disclose your information where we believe it is necessary to investigate, prevent, or act regarding our legal rights, including potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
With your consent. We may disclose your personal information for any other purpose with your consent.
In Short: Cookies are a small file on your computer (or other device) that may passively gather information about you. Google Analytics is a web analysis service provided by Google, which helps us better understand your use of the Sites and how we may improve them.
Cookies. By placing a small file known as a “cookie” on your computer (or other device), we and our third-party service providers’ servers may passively gather information about your use of the Sites for several reasons, including, but not limited to, the following: statistics collection and analysis, Site optimization, analytics, and maintenance of login information. The information that we and our third party service providers may track with cookies includes, but is not limited to, the type of browser (which as Google Chrome or Internet Explorer) and Internet-connected devices being used to access the Site, your IP address, your home domain or internet service provider, your referrer URL (which is the URL for the website that you were viewing prior to visiting the Site), how you were directed to the Site, which specific pages you access on the Site, how long you view each page, the time and date you access our Site and the total number of visitors to the Site and any portions thereof. We, and/or out third-party service providers, may use the information collected from cookies or similar files on your computer for security purposes (such as authentication), to facilitate Site navigation and to personalize your experience with visiting the Sites. This data may help us and our third-party service providers improve our respective products and services.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented commercially reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that you information or the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission to and from our Sites is at your own risk. You should only access the services within a secure environment.
7. DO WE LINK TO OTHER WEBSITES?
8. WHAT SHOULD I EXPECT WHEN POSTING TO OUR SOCIAL MEDIA?
In Short: Any posting to our pages contained on a social media platform or website is done at your own risk.
Any information, communications, or material of any type or nature that you submit to any of our pages contained on a social media platform or website by email, posting, messaging, uploading, downloading, or otherwise is done at your own risk and without any expectation of privacy. We cannot control the actions of other users of a social media platform, and we are therefore not responsible for any submissions contained on a social media platform or website.
9. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years. By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites. If we learn that personal information from users less than 18 years of age has been collected, upon request, we will deactivate the registration and take reasonable measures to delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at firstname.lastname@example.org.
10. DO WE ACCEPT JOB APPLICATIONS?
In Short: We accept job applications, and we and third parties may collect your personal information for that purpose.
Any personal information that you provide us when applying for a career position with us will be used solely to consider and act upon your application. We retain your personal information for a period, but only for as long as necessary for such purposes. We may disclose your personal information to our agents and/or third-party service providers for the purpose of evaluating your qualifications for the position you applied for, or other available positions. We may also disclose your personal information to third parties hired by us to collect, maintain, and analyze candidates for career positions.
11. WHAT ARE YOUR PRIVACY CHOICES?
In Short: You may review, change, or terminate your registration account at any time and opt out of promotional correspondence.
Promotional Correspondence: We may send you emails with promotional offers only if you opt-in to receiving such emails. If you would no longer like to receive information, newsletters, or other promotional messages from us, please click the link at the bottom of any such email you receive from us or follow the instructions. Please allow a reasonable timeframe to satisfy your request, as some promotions may already be in progress.
Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove or reject cookies, this could affect certain features of our Sites.
12. DO WE HONOR “DO NOT TRACK” REQUESTS?
In Short: We do not honor “Do Not Track” requests.
13. DO YOU HAVE OTHER DATA PROTECTION RIGHTS?
In Short: Potentially, subject to applicable data protection laws.
Subject to applicable data protection laws, you may have the right to access, update, correct, and delete your personal information. Please send such requests to the e-mail address located below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information.
15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
Atrium Campus, LLC
177 Huntington Ave Ste 1703
Boston, Massachusetts 02115-3153
Phone: (800) 403-0210
16. CALIFORNIA CONSUMER PRIVACY ACT RIGHTS
This Section 16 applies only to “consumers” (as defined under the California Consumer Privacy Act (“CCPA”)).
You have the right to request that businesses that are subject to the CCPA (which may include your school) disclose certain information to you about their collection and use of your personal information over the past 12 months. In addition, you have the right to ask such businesses to delete personal information collected from you, subject to certain exceptions. If you request deletion, you may have to be unenrolled from the applicable program(s) that you have previously enrolled in. If a business sells personal information, you have a right to opt-out of that sale. Businesses may not discriminate against you for exercising any CCPA rights, such as the access and deletion rights described above.
Should the CCPA apply to us, we act as a “service provider” under the CCPA and our receipt and collection of any consumer personal information is done on behalf of our business partners (such as schools) for us to provide services to our business partners and customers. Please direct any requests for access or deletion of your personal information under the CCPA to the business (which may include your school) with which you have a direct relationship.