PRIVACY POLICY OF CAMPUSTAP

1. INTRODUCTION

The Smart Campus, LLC, d/b/a CampusTap (also referred herein as “our”, “we”, or “us”), knows that you (our student, faculty, administrative, institutional and employer and other users – collectively “Users”) care about how your information is stored and shared. This Privacy Policy (“Policy”) explains the type of information we may collect from you when you visit the CampusTap, www.thecampustap.com (our “Website”) or through any mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website (collectively the “Website Applications”, and together with the Website, “CampusTap”). We will not use or share any of your information except as described in this Policy.

This Policy applies to information we collect:

On this Website;

In e-mail, text and other electronic messages between you and this Website;

Any Website Applications; or

When you interact with our advertising and Applications on third-party websites and services, if those applications or advertising include links to this Policy

This Policy does not apply to information collected by:

Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or

Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use CampusTap. By accessing or using CampusTap, you agree to this Policy. This Policy may change from time to time (see Changes to our Privacy Policy at http://thecampustap.com/privacy). Your continued use of CampusTap after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

Please be aware that any personal information you voluntarily disclose online becomes publicly available, and can be read collected, used by others and could be used to send unsolicited messages to your email and/or mobile device. CampusTap is not responsible for information that you choose to disclose publicly or through CampusTap’s services.

2. INFORMATION CAMPUSTAP COLLECTS.

2.1. Data Controller.

Personal information provided to or gathered by CampusTap is controlled by The Smart Campus, LLC 26 Sanborn Lane Reading, MA 01867

2.2. Registration Information.

CampusTap’s minimum requirements for account registration are name, email address, password, age, gender and school where you are a student, or the company or organization you represent. You may voluntarily provide additional information about yourself during the registration process, such as gender and location. We use any additional information to provide you with customized services such as updates, content, relevant advertisements, event notifications and career opportunities. Such additional information may appear on your CampusTap profile and may be used by CampusTap in accordance with this Policy and CampusTap’s Terms of Use located at http://thecampustap.com/terms

2.3. Profile Information.

When creating your CampusTap profile, you may, at your sole discretion, provide certain other information, such as event times and locations, interests, hobbies, age, gender, sexual orientation etc., that may be displayed to other Users and on third-party websites and services (including Twitter, Facebook, etc.) in accordance with your privacy settings.

2.4. Location Information.

CampusTap collects, maintains, uses and displays your personal data and geographic location of your mobile device (“Geo-location”) to provide our services. By using CampusTap, you have consented to:

(a) The use of your Geo-location to provide our services included targeted event notifications, advertisements and the display of that location information to your friends using CampusTap and within your location based tagged messages and content;

(b) Receive push notifications, text messages and emails regarding your CampusTap account and CampusTap activity; and

(c) Pay carrier data, messaging and other fees resulting from CampusTap usage.

CampusTap’s default privacy setting are initially set to save your password for Website Applications, update your Geo-location automatically and display such information to other CampusTap Users, even when CampusTap is not open or running on your device. If you wish to change these settings, please refer to CampusTap’s “Settings” section.

2.5. Cookies.

CampusTap uses cookies and similar technologies to help us recognize you, improve your CampusTap experience, increase security and to analyze how you use CampusTap services. You can control cookies through your web browser’s “Help” settings.

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

2.6. Log Files and Information Relating to Your Computer or Mobile Device.

When you use CampusTap, our servers automatically record certain information regarding your usage. Server logs may include information mobile device identification number, device identifier, IP addresses, web requests, browser type, browser language, referring exit pages and URLs, platform type, number of clicks, domain names, search terms, ratings, landing pages, order of pages viewed, CampusTap features used, number of friend requests, messages, time spent on certain screens, dates and times of friend requests and messages and specific cookies that may identify your browser.

2.7. Inviting New Users to CampusTap.

If you invite new users to take advantage of CampusTap’s services, through CampusTap’s website or mobile application, CampusTap may provide you with a unique referral link to track your activity and interactions with individuals who are not yet members of the CampusTap community. However, at no time will individuals’ information be collected or stored if they have not registered for a CampusTap account.

3. HOW CAMPUSTAP USES YOUR INFORMATION.

(a) Personal information you provide in your CampusTap profile may reveal or enable others to identify elements of your life that you did not expressly state in your profile, such as your gender from looking at your profile picture. Personal information that you voluntarily disclose for posting, including Geo-location information and profile content, becomes available to the public. CampusTap is not responsible for the dissemination of personally identifiable, profile or location information that you choose to disclose publicly on CampusTap. Even if you remove such information from CampusTap, copies may remain viewable via cached and archived pages of CampusTap, or if other Users copied or saved such information.

(b) When you are running CampusTap on your mobile phone, CampusTap shows your mobile phone’s Geo-location to your CampusTap contacts as controlled by your privacy settings.

(c) By registering for CampusTap, you consent to CampusTap using the email address provided by you, to send service-related notices and notices required by law, instead of communication by standard mail. CampusTap may also use your email address or mobile phone number to send you push notifications, messages, newsletters, changes to CampusTap services, or special offers based on your activity on CampusTap. You may opt out of any of these communications by changing your preferences on CampusTap. Opting out may prevent you from receiving updates, improvements or special offers. You may not opt out of CampusTap service-related emails. CampusTap reserves the right to retain the content of your emails, messages and responses created during correspondence with CampusTap or its representatives.

(d) CampusTap may use certain information about you and/or your User content without identifying you as an individual to third parties. CampusTap does this to analyze how our services are used, to provide analytics, to diagnose technical problems, to maintain security and to personalize content. CampusTap reserves the right, but has no obligation, to monitor content you post on the mobile application or website. CampusTap reserves the right to remove any such information or material for any reason or no reason, including if such information, in our opinion, violates or may violate any applicable law or CampusTap policies relating to usage, or to protect or defend our rights or property or those of any third party or other User. CampusTap also reserves the right to remove any User information upon the request of any third party.

4. HOW CAMPUSTAP SHARES YOUR PERSONAL INFORMATION.

4.1. Personally Identifiable Information.

(a) CampusTap may share your personally identifiable information with third parties solely for the purpose of providing you with services related to your CampusTap experience. Such third parties’ use of your information, as provided by CampusTap, shall be bound by this Policy. We may store your personal information in servers or locations outside the direct control of CampusTap, such as a third-party hosting provider.

(b) CampusTap does not share your personally identifiable information or personally-identifiable location information with other, third-party companies for their commercial or marketing use without your express consent or unless you have opted-in to be part of a specific program or feature. CampusTap cannot control third parties’ use of your personally identifiable information. Please do not participate in such programs or features if you do not want your information to be collected by or shared with third parties. If you choose to share your personally identifiable information, you will be granting such third-party the right to store, access and disclose and use your CampusTap contact information in the ways described in such third party’s terms and privacy policy.

4.2. Groups.

You may choose to participate in CampusTap groups, which are based on your personal interests and which share content with your CampusTap network, or import information or other content from outside of CampusTap’s network, you should note that any of this information can be read, collected, and used by other Users in these forums, developers and other third parties. CampusTap is not responsible for the information you choose to submit in these forums. Some content located on CampusTap group pages may be public and searchable on the Internet if the group administrator has not closed the group for public viewing and/or discussions.

4.3. Subscribers.

CampusTap allows subscribers, such as companies, professional organizations or other enterprises to export information from User profiles, such as name, college/university, year of graduation, major and professional interests to effectively manage job candidate pools. You may limit or prevent certain subscribers from exporting such information by adjusting your CampusTap settings. No email or other contact information will be provided to subscribers described in this Policy. You should note that any information posted on your profile is available to other Users and subscribers described in this Policy. For example, professional recruiting companies may store information independent of information you have provided through CampusTap, such as a resume. Any personally identifiable information obtained independent of CampusTap’s services are not under CampusTap’s control but are subject to the policies of the particular subscriber.

4.4. Profiles for Companies, Schools and Other Organizations.

CampusTap permits companies, colleges/universities, charities, other employers and professional organizations to create profiles dedicated to their business or professional field. These profiles are public and communications or other information shared through them is accessible by the profile creator for that organization. If you choose to follow a profile, you may show up on a list of followers, which can be viewed by other Users. The reason for this is to compile data about followers and viewers, and to track the specific performance of profiles created by the aforementioned organizations.

4.5. Disclosure to Third Parties as the Result of Change in Control or Sale of CampusTap.

As CampusTap develops and grows, we may buy or sell assets or business offerings. In the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Campus Tap’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by CampusTap about our Website users is among the assets transferred, we will likely transfer your personal information to the acquiring party.

4.6. Compliance with Legal Process and Other Disclosures.

Except as otherwise stated in this Policy, CampusTap will not disclose any personal information to third parties unless required to do so by law or subpoena or if we believe that such action is necessary to (i) conform to the law, (ii) comply with legal process served on us or our affiliates, (iii) investigate, prevent, or take action regarding suspected or actual illegal activities, (iv) to enforce CampusTap’s Terms of Use, (v) take precautions against liability, (vi) investigate and defend ourselves against third-party claims or allegations, (vii) assist government enforcement agencies, (viii) protect the security or integrity of CampusTap’s website or mobile application and ©, or (ix) to exercise or protect the rights, property or personal safety of Users or others.

4.7. Non-Personally Identifiable Information.

(a) CampusTap may share non-personally identifiable information such as anonymous usage date, referring or exit pages and URLs, platform types and number of clicks with interested third parties to help them understand usage patterns for certain CampusTap services.

(b) CampusTap may allow third-party ad servers or ad networks to serve advertisements on the CampusTap mobile website and application. These third-party ad servers or networks use technology to send, directly to your browser, the advertisements and links that appear on CampusTap. They automatically receive your IP address when this occurs. Other technologies such as cookies, JavaScript or web beacons may also be used by such third parties to measure the effectiveness of their advertisements and to personalize advertising content. CampusTap does not provide any personally identifiable information to these third-party ad servers or networks without your express consent. However, if an advertiser asks CampusTap to show an advertisement to a certain audience and you respond to that advertisement, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach. The CampusTap Privacy Policy does not encompass, and CampusTap cannot control the activities of, third-party advertisers. For more information, please consult the privacy policies of such advertisers.

5. HOW CAMPUSTAP PROTECTS YOUR INFORMATION.

5.1. Security.

(a) We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any personally identifiable information that is not publicly disclosed by you will be encrypted using SSL technology.

(b) The safety and security of your information 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 you password with anyone. We urge you to be careful about giving out information in public areas of the Website, such as message boards or via your profile depending on your CampusTap privacy settings. The information you share in public areas may be viewed by any User.

(c) Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

5.2. Compromise of Personal Information.

In the event of a security breach which results in the compromise of personal information, CampusTap shall promptly notify the Users whose personal information has been compromised, in accordance with the notification procedures set forth in this Policy, or as otherwise required by applicable law.

6. CHILDREN’S PRIVACY.

CampusTap does not knowingly collect or maintain personally identifiable information on CampusTap’s website or mobile application from persons under 14 years of age, and no part of CampusTap’s services is directed to persons under 14. IF YOU ARE UNDER 14 YEARS OF AGE, PLEASE DO NOT USE, ACCESS OR REGISTER FOR CAMPUSTAP SERVICES AT ANY TIME. CampusTap reserves the right to immediately remove and delete any information, whether personally identifiable or otherwise, of persons less than 14 years of age, without verifiable consent by a parent or legal guardian. If you are a parent or guardian and discover that your child under age 14 has obtained a CampusTap account, please alert CampusTap immediately and request the deletion of the child’s information from CampusTap’s systems.

7. FERPA COMPLIANCE.

Below describes our provision for compliance with the Family Educational Rights and Privacy Act.

The student records policy of CampusTap is governed by the Family Education Rights and Privacy Act (FERPA). No one will have access to nor will the company disclose any information from a student educational record without the written consent of the student except to personnel within the institution, to officials of other institutions in which the student seeks to enroll, to persons or organizations providing the student financial aid, to accrediting agencies carrying out their accreditations function, to authorized representatives of state and federal governments for audit and review of state and federal supported programs, to persons in compliance with a judicial order and to persons in an emergency in order to protect the health and safety of students or other persons. All aforementioned exceptions are permitted under FERPA.

All student information, except for the college or university where you are a student, is provided voluntarily by you. You are not required to provide additional educational information in order to register for CampusTap’s services. Your educational records that may be kept on CampusTap may include:

Personal or biographical data as gathered through the CampusTap registration process

Course enrollment

Event registration and participation

Grades

Club enrollment and participation

These educational records are under the direct supervision and coordination of the club or other relevant administrator. If you wish to review any of your records, you may do so by contacting the club or other administrator, or by contacting info@campustap.com with a formal request for a specific set of records.

We may use student directory information for internal functions. This information may include:

Name

Grade

Gender

Participation in events, activities, sports, meetings officially recognized by your college or university

Registered email address

Mailing address

Work experience

Awards received

Dates of use of our services

Your most recent educational institution attended

8. INTERNATIONAL USERS.

CampusTap may transfer and access data about CampusTap Users from around the world, including the United States. This Policy shall apply even if CampusTap transfers data about CampusTap Users to other countries.

9. DEACTIVATION AND DELETION OF YOUR CAMPUSTAP ACCOUNT.

9.1. Deactivation.

You may deactivate your CampusTap account at any time. This will put your account on hold. Although other CampusTap Users will not be able to view your information, your information will not be deleted. Deactivation notifies CampusTap that you may want to return to CampusTap at a later date, which is way CampusTap stores your information until you decide to reactivate your account.

9.2. Deletion.

You may decide that you never want to return to CampusTap. If you choose to delete your account, no future information will be stored or shared regarding your account. However, due to the analytical nature of CampusTap and CampusTap’s goal to provide cutting edge solutions for students, faculty, employers and its Users in general, your prior activity on CampusTap will not be deleted. Please note that your personally identifiable information will never be shared after you delete your account and non-personally identifiable information may be used, but only for future analysis.

10. CAMPUSTAP USER OBLIGATIONS.

As a CampusTap User, you have certain obligations to other Users. Some of these obligations are required by law and others are customary for social networks with similar characteristics to CampusTap.

10.1. Terms and Conditions.

You must abide by the terms and conditions of this Policy, CampusTap’s Terms of Use and all other CampusTap policies. These policies include protection for the intellectual property rights of third parties. CampusTap reserves the right to remove any material that we believe to be infringing or that a third party alleges is infringing and will abide by all applicable laws and procedures with respect to each.

10.2. Violations.

Any violation of this Policy, other CampusTap policies or applicable law may lead to the restriction, suspension or termination of your account. CampusTap solely reserves the right to take any and all necessary actions as described in this Policy or by applicable law.

11. QUESTIONS ABOUT THIS POLICY.

If you have questions regarding CampusTap’s Privacy Policy, the practices of CampusTap, or your user relationship with CampusTap’s website or mobile application, please contact CampusTap at info@thecampustap.com.