Welcome!

Welcome to CampMinder. We take your privacy seriously and know you do too. This Privacy Policy (“Policy”) is here to help you understand how we collect, use, disclose, and process your personal data. We also describe Your Rights and Choices with respect to how we process your personal data. Please read this Policy carefully.

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.

Applicability

This Privacy Policy applies to our “Services”, which include our websites that link to/post this Privacy Policy, including any subdomains or mobile versions (the “Site(s)”) and mobile applications (the “Mobile App(s)”).

Agreement

This Policy is incorporated into the Terms of Use governing your use of any of our Services. Any capitalized terms not defined in this Privacy Policy will have the definitions provided in our Terms of Use.

Following notice to you or your acknowledgment of this Privacy Policy (including any updates), your continued use of any of our Services indicates your consent to the practices described in this Policy.

Third Parties

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.

Mobile Apps

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.

Staffing 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 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.

Administration 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.

Marketing Communications

Data:  We may process Identity Data and Contact Data in connection with email marketing communications, including (i) on behalf of Clients, when you register for an account, and choose to enroll, or are enrolled by the Client, to receive marketing communications; (ii) on behalf of Clients, when you open or interact with, a Client’s electronic marketing communications; (iii) on our own behalf when you contact us directly, or express an interest in our products and services; and (iv) on our own behalf when you open or interact with our marketing communications.

Uses:  We use Identity Data and Contact Data as necessary to provide marketing communications, and consistent with our legitimate business interests, we may send you marketing and promotional communications if you sign up for such communications or purchase services from us. See Your Rights and Choices for information about how you can limit or opt out of this processing.

Additional Processing

If we process Personal Data in connection with our Services in a way not described in this Policy, this Policy will still apply generally (e.g. with respect to Your Rights and Choices) unless otherwise stated when you provide it.

Note that we may, without your consent, also process your Personal Data on certain public interest grounds. For example, we may process information as necessary to fulfill our legal obligations, to protect the vital interests of any individuals, or otherwise in the public interest. Please see the Data Sharing section for more information about how we disclose Personal Data in extraordinary circumstances.

Data Sharing

Generally

Information we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer Personal Data to the following categories of recipients:

Clients:  We process data on behalf of Clients, and may share your Personal Data with Clients to the extent such information was provided to us for processing on the Client’s behalf. For example, any forms, applications, messages, or other material may be processed by us for Clients, and all Personal Data processed on behalf of the Client may be available to the Client and its users. These parties may engage in direct marketing, or other activities that are outside our control.

Service Providers:  In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other legitimate business interests, we may share your Personal Data with service providers or subprocessors who provide certain services or process data on our behalf.

Affiliates:  In order to streamline certain business operations, develop products and services that better meet the interests and needs of our customers, and inform our customers about relevant products and services, we may share your Personal Data with any of our current or future affiliated entities, subsidiaries, and parent companies.

Corporate Events:  Your Personal Data may be processed in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.

Legal Disclosures:  In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data, any communications sent or received by you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms of Use, or in the vital interests of us or any person. Note, these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Data as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Data to such parties.

Your Rights & Choices

Your Rights

To the extent required under applicable law, and subject to our rights to limit or deny access/disclosure under applicable law, you have the following rights in your Personal Data. You may exercise your rights by contacting us at the address below.

Access:  You may receive a list of your Personal Data that we process to the extent required and permitted by law.

Rectification:  You may correct any Personal Data that we hold about you to the extent required and permitted by law. You may be able to make changes to much of the information you provided directly via the Service via your account settings menu.

Erasure:  To the extent required by applicable law, you may request that we delete your Personal Data from our systems.

Data Export:  To the extent required by applicable law, we will send you a copy of your Personal Data in a common portable format of our choice.

Direct Marketing:  Residents of California (and others to the extent required by applicable law) may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year. This request must be written, signed, and mailed to us.

Regulator Contact:  You have the right to contact or file a complaint with regulators or supervisory authorities about our processing of Personal Data. To do so, please contact your local data protection or consumer protection authority.

We may require that you provide additional Personal Data to exercise these rights, e.g. information necessary to prove your identity.

Your Choices

It is possible for you to use some of our Services without providing any Personal Data, but you may not be able to access certain features or view certain content. You have the following choices regarding the Personal Data we process:

Consent:  If you consent to processing, you may withdraw your consent at any time, to the extent required by law.

Direct Marketing:  You have the choice to opt-out of or withdraw your consent to processing related to direct marketing communications. You may have a legal right not to receive such messages in certain circumstances, in which case, you will only receive direct marketing communications if you consent. You may exercise your choice via the links in our communications or by contacting us re: direct marketing.

Location Data:  You may control or limit Location Data that we collect using our Mobile App by changing your preferences in your device’s location services preferences menu, or through your choices regarding the use of Bluetooth, WiFi, and other network interfaces you may use.

Cookies & Similar Tech:  If you do not want information collected through the use of cookies, you can manage/deny cookies (and certain technologies) using your browser’s settings menu. You must opt out of third-party services directly via the third party. For example, to opt-out of Google’s analytics and marketing services, visit Google Analytics Terms of Use, the Google Privacy Policy, or Google Analytics Opt-out. To learn more about how to opt out of Google’s use of cookies, visit Google’s Ads Settings, here. Please note, at this time, our Service does not respond to your browser’s do-not-track request.

Other Processing:   You may have the right under applicable law to object to our processing of your Personal Data for certain purposes. You may do so by contacting us re: data rights requests. Note that we may not be required to cease processing based solely on an objection.

Note Regarding Clients’ Data

CampMinder is a processor of Clients’ personal data. We may notify Clients of your data rights requests, however, we may be unable to directly fulfill rights requests regarding Personal Data unless we control or have the necessary rights of access. CampMinder may not have access to or control over all or some Personal Data controlled by Clients. Please contact the Client directly for data rights requests regarding Client-controlled information, and we will assist the Client as appropriate in the fulfillment of your request. Please note that, to the extent we make interfaces available for you to directly control your data, these will take effect only with respect to the data on our Service, and Clients may have additional copies of this information that is outside of our control.

Security

We follow and implement reasonable security measures to safeguard the Personal Data we process. However, we sometimes share Personal Data with, or process data on behalf of third parties, as noted above. While we may require our service providers to follow certain security practices, we do not have control over and will not be liable for third parties’ security processes. We do not warrant perfect security and we do not provide any guarantee that your Personal Data or any other information you provide us will remain secure.

Data Retention

We retain Personal Data for so long as it remains relevant to its purpose, and in any event, for so long as is required by law. As we process Personal Data on behalf of Clients, we may retain information for the periods requested by the Client or delete information at the Client’s request. We will review retention periods periodically, and if appropriate, we may pseudonymize or anonymize data held for longer periods.

Minors

Our Services are intended for use by Clients and campers’ parents, and are neither directed at nor intended for direct use by individuals under the age of 16. Further, we do not knowingly collect Personal Data directly from such individuals. If we learn that we have inadvertently done so, we will promptly delete it. Do not access or use the Services if you are not of the age of majority in your jurisdiction unless you have the consent of your parent or guardian.

International Transfers

We operate and use service providers located in the United States. If you are located outside the U.S., your Personal Data may be transferred to the U.S. The U.S. does not provide the same legal protections guaranteed to Personal Data in the European Union. Accordingly, your Personal Data may be transferred to the U.S. pursuant to the EU-U.S. Privacy Shield Framework, the Standard Contractual Clauses, or other adequacy mechanisms, or pursuant to exemptions provided under EU law.

EU-U.S. Privacy Shield

We comply with the EU-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce with respect to the processing of Personal Data from European Union member countries as described in this Privacy Policy. We have certified that we adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. Furthermore, we require third party recipients of EU residents’ Personal Data to agree to respect these principles, and we accept liability for third parties’ processing of EU residents’ data to the extent required by law.

If there is any conflict between this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov. You may view the list of Privacy Shield companies here.

We encourage users to contact us if you have any concerns about our compliance with this Privacy Policy and the Privacy Shield Framework. In compliance with the EU-U.S. Privacy Shield Principles, we commit to resolving complaints about your privacy and our collection or use of your Personal Data. EU residents with inquiries or complaints regarding this Privacy Policy should first contact us at the address below. We will respond to complaints from EU residents within 45 days.

If any complaints by EU residents cannot be resolved informally, we have agreed to participate in the JAMS dispute resolution procedures pursuant to EU-U.S. Privacy Shield principles. EU residents with unresolved complaints may refer them to JAMS here. Under certain circumstances, these dispute resolution processes may result in your ability to invoke binding arbitration. As a U.S. company, we are also subject to the investigatory and enforcement power of the FTC regarding our compliance with the Privacy Shield Framework and this Privacy Policy, and users may direct complaints to the FTC in the event the dispute resolution processes described above is unsatisfactory.

In compliance with the Privacy Shield Principles, CampMinder commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact CampMinder at:

issues@campminder.com

CampMinder has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Changes to Our Privacy Policy

We may change this Privacy Policy from time to time. Changes will be posted on this page with the effective date. Please visit this page regularly so that you are aware of our latest updates. Your acknowledgment of these changes, or use of the Services following notice of any changes (as applicable) indicates your acceptance of any changes.

Contact Us

Feel free to contact us with questions or concerns using the appropriate address below.

General inquiries:

info@campminder.com

Physical address:

CampMinder, LLC

5766 Central Avenue

Boulder, CO 80301

Phone: 303-444-2267

List of Third Parties

Unaffiliated Parties and Partners

The following is a list of unaffiliated third parties with whom we may share data or which may engage in processing:

 

Third Party Data Sources
Amazon Web Services Vendor – Hosted CM Desktop – Camp In Touch environment housing all details associated with clients of our clients including name, address, date of birth, gender and contact information.
Microsoft Vendor – Hosted campminder.system test environment. Houses all CampMinder system database details.
RackSpace Vendor – Hosted Microsoft Azure Production environment, managed by Rackspace. Houses all CampMinder system database details.
SendGrid Vendor – Email service that enables the transmission and storage of email traffic between our clients and their clients through the CampMinder system.
Flexential Vendor – PCI compliant server environment where transaction data is stored; data includes payments made to our clients by their clients for registration fees.
Alachisoft Vendor of NCache, a product that provides an extremely fast and linearly scalable distributed cache that caches application data.
Geotrust Vendor – SSL certificate which provides secure, encrypted communications between a website and an internet browser.
Vinta Soft Vendor – Provides image processing service as part of our summer services offered as an option through our Camp In Touch service.
Wistia Vendor – Provides video hosting service for clients that provide videos to their clients as part of our summer services offered as an option through our Camp In Touch service.
District Photo Vendor – Provides photo processing, printing and shipping of images presented for purchase by the clients of our clients through the Camp In Touch platform as part of our summer services offered as an option through our Camp In Touch service. Digital images viewed in the Camp In Touch platform are available for purchase. Purchaser information stored in the service include name, address, payment method information, phone number and email address.
Salesforce Vendor – Provides a customer relationship management platform. Here we store client contact information including name, address, phone number and email address.
Bill.com Vendor – Provides a bookkeeping platform where we store information including client banking information, client contact information including name, address, phone number and email address
Quickbooks Vendor – Provides an accounting and general ledger platform where we store client information including name, address, phone number and email address.
NMI Vendor – Payment gateway solution for epayments and credit card transactions. Data stored includes payors name, payment method details, payment amount and date of payment.
Camp Takajo, Camp Manitou, Tripp Lake Camp, Camp Lenox, Camp Wingate Kirkland, Camp Greystone, Alpine Camp for Boys, AdventureTreks, Camp Highlander, Falling Creek Camp, Camp Huawni, Camp Pinnacle, Camp Romaca, Camp Young Judaea Texas, Camp Granite Lake, Everwood, Rolling River Day Camp, Green River Preserve, Camp Highland, International Sports Training Camp, Camp River Way, SuperCamp, Camp Alonim, YMCA New York, Camp Skyline, Raquette Lake, Camp Woodward East (PA), Camp Woodward West, Yachad, Asphalt Green Summer Day Camp, NCSY Summer Programs, Camp Mystic, Camp Ramah in Wisconsin / Ramah Day Camp, Harlam, 6 Points Sports Academy, Six Points Sci Tech, OSRUI,

Concordia Language Villages, Nobles Day Camp, YMCA Vanderbilt, Camp Cody, Camp Coleman, Camp Greene, Camp Kalsman, Camp Eisner, Camp Crane Lake, Camp Newman, URJ Camp George, URJ GUCI, URJ Henry S. Jacobs Camp, URJ NFTY EIE, URJ Mitzvah Corps, URJ NFTY in Israel, URJ Kutz Camp, Camp Green Leaf, Coleman Country Day Camp, URJ NFTY, URJ 6 Points Sports Academy CA, PALS Program, YMCA Camp Tecumseh, Camp Fitch YMCA, Cape Cod Sea Camps, URJ Sci-Tech West, URJ Arts, URJ Teen Travel, URJ RAC

Clients also known as Camps – These clients use an API key provided by CampMinder to integrate only their specific data that is owned by them with same clients’ marketing and/or customer relationship management platform that is independent of the CampMinder platform.