Effective December 21, 2018
Who We Are
This is the Policy of CampMinder LLC (“CampMinder,” “us,” “our,” or “we”), a Colorado company with offices at 5766 Central Avenue, Boulder, CO 80301. You can contact us here.
CampMinder is a service provider for camps and other clients (“Clients”). Our Services enable our Clients to connect with, support, and provide services to parents, client customers, as well as the Client’s administrators and staff. In each case, we provide a platform for use by Clients, and this Policy reflects the data processed and activities undertaken through our Services. However, the Policy does not apply to the Client’s own uses of your data, including processing they may choose to undertake that is not described in, or different from, this Policy.
This Policy also does not apply to information processed by other third parties, for example, when you visit a third-party website or interact with third-party services, unless and until we receive your information from those parties. Please review any third parties’ privacy policies before disclosing information to them. See our list of third parties for more information regarding our sources and recipients of personal data.
Collection and Use of Personal Data
Data We Collect
We collect and process the following types of information, including data that relates to identified or identifiable individuals (“Personal Data”) (note, specific Personal Data elements listed in each category are only examples and may change):
Identity Data: Personal Data about you and your identity, such as your name, ID/driver’s license number, gender, marital status, date of birth, social security number, photo/avatar, username, and other Personal Data you may provide on applications, registration forms, or as part of an account profile (e.g. biographical information).
Transaction Data: Personal Data we collect in connection with a transaction or purchase, such as the item you purchased, the price, the delivery location, zip code, and other similar information.
Contact Data: Personal Data used to contact an individual, e.g. email address(es), physical address(es), phone number(s), or social media or communications platform usernames/handles, as well as a name or other salutation.
Financial Data: Personal Data relating to financial accounts or services, e.g. a credit card, bank, or other financial account numbers, and other relevant information you provide in connection with a financial transaction.
Device Data: Personal Data relating to your device, browser, or application e.g. IP addresses, MAC addresses, application ID/AdID/IDFA, identifiers from cookies, session navigation history and similar browsing metadata, and other data generated through applications and browsers, including cookies and similar technologies.
Location Data: Personal Data relating to your precise location, such as information collected from your device’s GPS or other precise localization service.
Special Category Data: Personal Data revealing racial, national, or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, health information, or information relating to sex life or sexual orientation.
Custom Content: Information that a user provides in a free text or other unstructured format, or pursuant to custom fields created by a Client; this may include Personal Data or Special Category Data to the extent provided by the user.
Processing of Personal Data
User Account Registration
Data: Users may register and create an account on our Services. When you register, we process certain Personal Data on behalf of the Client, which typically includes Identity Data and Contact Data. We may also process certain Financial Data if you choose, for example, to purchase products and services through our Service.
Uses: On behalf of the Client, we use Identity Data and Contact Data as necessary to create, maintain, and provide you with important information about your account. Financial Data provided at registration will be used only as necessary to process transactions at your request or to store payment information for future purchases. Subject to Your Rights and Choices, we may also use Identity Data as part of our efforts to improve our Services, and on behalf of the Client, we may process Identity Data and Contact Data in connection with marketing communications.
Client and Family Application/Registration
Data: Client’s users may submit inquiries, camper applications, medical and other forms, and register with Clients through our Services. When you submit an application or register with a Client, we process certain Personal Data on behalf of the Client, which typically includes Identity Data, Contact Data, and Financial Data, and if requested by the Client, Custom Content and Special Category Data.
Uses: On behalf of the Client, we use all Application/Registration data as necessary to provide our Services to the Clients, including in connection with the assessment of applications and prospective applicants, and creation of the Client-Camper relationship. Financial Data provided in connection with any application/registration will be used only as necessary to process transactions you request. Subject to Your Rights and Choices, we may also use Identity Data, Contact Data, and Custom Content on behalf of Clients: (i) in connection with the maintenance of Camper records, which may include family/guardian relationships, emergency contact information, mailing addresses, etc.; (ii) to provide marketing or other communications between Clients and parents; and (iii) along with Special Category Data, in accordance with your consent provided to the Client (e.g. to provide health services, adjusting meal options, etc.), and where permitted by law, to maintain records relating to the health and treatment of campers by the Client.
Purchases & Donations
Data: On behalf of the Client, we process Transaction Data, Identity Data, Financial Data, and certain Contact Data when you complete a purchase from or donate to a Client through our Services. Note, all purchases and donations are processed by a third party on behalf of us or the Client, however, we and/or the Client may obtain any Personal Data processed by that third party.
Uses: On behalf of the Client, we use the Transaction Data, Identity Data and Contact Data as necessary to complete and provide you with important information regarding your transaction, or in connection with certain recordkeeping the Client may wish to undertake. Financial Data is used only as necessary to process your transaction, and if you request, we may store your Financial Data for future purchases. Subject to Your Rights and Choices, we may process the Transaction Data and Identity Data to improve design and delivery of our Services, and on behalf of the Client, to keep a record of donors and donations, or in connection with marketing communications.
Client Comments, Messaging & Custom Content
Data: On behalf of the Client, we process Identity Data, Contact Data, and if provided, Custom Content when you use our Services to fill out forms relating to Clients, message the Client or send a message to a camper, or if you otherwise submit any Custom Content (e.g. on a comment board or other free-form content submission form).
Uses: On behalf of the Client, we use Identity Data and Contact Data as necessary to carry out the processes and transactions you request. Subject to Your Rights and Choices, we may also use Identity Data and to improve our Services and, on behalf of the Client, we may make certain Custom Content and Identity Data, including information (such as name) derived from analysis of faces that appear in photos, contained in Client photos and videos available on our site for viewing by parents and Client Administrators, and we may process Identity Data and Contact Data in connection with marketing communications.
Note: We do not screen messages, comments or other postings for personal or inappropriate content.
Events, Planning and Client Activities
Data: On behalf of the Client, we may process Identity Data and Contact Data, and if requested by the Client, Custom Content and Special Category Data in connection with the management of events, trips, and other activities at the Client, as well as Client administration.
Uses: On behalf of the Client, we use this personal data as necessary for the Clients to manage these activities. Subject to Your Rights and Choices, we may also use Identity Data, Contact Data, and Custom Content on behalf of Clients: (i) in connection with the maintenance of event-related administrative camper records, e.g. Client and event scheduling and attendance records, building/room/bus/seat assignments or other data relating to transportation use, counselor assignments, event description/destination, etc., and (ii) along with Special Categories Data, in accordance with your consent provided to the Client (e.g. to provide health services, adjusting meal options, etc.) and where permitted, to maintain records relating to the health and treatment of users by the Client.
Data: If you use our Mobile Apps, we process certain Personal Data on behalf of the Client, which typically includes Identity Data, Contact Data, Device Data, and, with your consent, Location Data. Note, you may also be able to complete purchases, register for an account, or enroll in marketing communications through our Mobile App.
Uses: On behalf of the Client, we process the Identity Data, Contact Data, and Device Data as necessary to create your account and deliver the Service and fulfill your requests. Subject to Your Rights and Choices, we may use the Identity Data, Contact Data, Device Data, and Location Data to improve our services, and we may process this Device Data and Location Data on behalf of the Client in connection with counsel location awareness features or other location services the Client may offer.
Data: On behalf of the Client, we may process Identity Data, Financial Data and Contact Data as well as certain Special Category Data in connection with an application to be a Client’s administrator, counselor, volunteer, or otherwise join or support a Client’s team, and where requested by the Client, in connection with criminal, professional, credit or other background checks relating to an applicant.
Uses: All staffing data will be used as is requested by the Client, as necessary in connection with these activities, or as required by law. Financial Data is collected and may be stored for payroll or reimbursement purposes, or as otherwise necessary in the context of the staffing relationship. Subject to Your Rights and Choices, we process this Personal Data on behalf of the Client, in connection with Clients’ activities in relation to the assessment, creation, maintenance, and termination of the staffing relationship, or in connection with various background checks relating to a prospective staff member.
Note: CampMinder may maintain relationships with background check providers, and Clients may direct CampMinder to assist in the request, fulfillment, and storage of background check information. However, Clients are the controllers of such information and are responsible for obtaining applicants’ consent, ensuring the legal rights of applicants, and for their use of background check data.
Data: On behalf of the Client, we may process Identity Data, Financial Data and Contact Data as well as certain Special Category Data in connection with administrative information collected by Clients, such as invoicing, expense reporting, financials, or other internal processes. This information may include medical information of certain staffers or campers, or other similar Special Categories data, to the extent provided by the staffer, camper, or parent.
Uses: On behalf of the Client, we process Identity Data, Financial Data and Contact Data primarily in connection with Clients’ internal business activities in relation to the analysis and internal reporting of Client financials, performance, or other activities. All administrative data will be used as is required by the Client as necessary in connection with these activities, or as required by law. Financial Data is collected and may be stored for payroll or reimbursement purposes, or as otherwise necessary in the context of the staffing relationship. Subject to Your Rights and Choices, we may process the Special Categories Data in connection with the individual’s consent, or as otherwise permitted by law.
Cookies and Similar Technologies
Data: We, and certain third parties, may process Device Data when you interact with cookies and similar technologies. We may receive this data from third parties to the extent allowed by the applicable partner. Please note that the privacy policies of third parties may apply to these technologies and information collected.
Uses: In connection with our legitimate interests in providing and improving the user experience and efficiency of our Services, and understanding information about the devices and demographics of visitors to our Services, we use this information (i) for “essential” or “functional” purposes, such as to enable various features of the Services such as your browser remembering your username or password, maintaining a session, or staying logged in after a session has ended; (ii) for analytics and site performance purposes, such as tracking how the Services are used or perform, how users engage with and navigate through the Services, what sites users visit before visiting our Services, how often they visit our Services, and other similar information; and (iii) for the purpose of displaying advertisements via retargeting to those users who may have demonstrated an interest in our Service.
Note: Some of these technologies can be used by third parties to identify you across platforms, devices, sites, and services. Clients may also have access to information, such as reports and analytics, generated through these services.