CAMPUS HUB, LLC


PRIVACY POLICY

I. Introduction
This Privacy Statement provides information on how Campus Hub LLC (“Campus Hub”) collects, uses, and protects personal information. As part of creating school management solutions, there may be times that personal employee and/or student information is entered into the Site, and we are committed to the highest standards of protection for personal data at all times. When we refer to “us,” “we,” “our,” or “Campus Hub” in this Privacy Statement, we are referring to Campus Hub and its affiliates. Privacy is a fundamental right for all individuals. Our clients entrust us with the personal information of both employees and parents, and students. On this basis, we take the responsibility attached to this information very seriously. 


This Privacy Statement governs all the manners in which Campus Hub collects personal information directly from you as an individual. Whether you are a visitor to our websites, request a trial of our products or a whitepaper, or any other communication with us (such as attendance at a conference or trade show), this Privacy Statement governs our use of personal information for products and services that we provide directly to you as what is known as a “data controller.” How we collect information and how we use information may differ based on our relationship with you as an individual. We have identified below the different relationships we may have with you, and our respective use of information we collect.


When a customer’s privacy statement/policy governs. If you are an end-user (parent or student, applicant or employee) of our customer (a school or school district) and you are using Campus Hub products and services through our customer (your school or school district), we are considered a “data processor.” In these cases, your school or school district’s privacy statement or privacy notice governs the use of any personal information. Our Privacy Statement does not supersede the terms of any agreements between us and your school or school district (our customer), nor does it affect the terms of any agreement between the student and the student’s school or school district.
II. What Information We Collect and How We Use It
The nature of the personal information we collect and how we use it depends on the context in which we collect that personal information. Please see the section below that applies to you.


A. Website Users.
You may visit any Campus Hub website without having to log in or provide any personal information. If you are on a Campus Hub website to access a service or product, you may need to log in to access certain pages, features, and/or functionality of the particular product.


Information We Collect Directly from you.

You may voluntarily provide us information when you complete a form or survey on our website. You may also provide information when you register for an account through a Campus Hub website to log in to use a product or service.
Indirectly from you. We collect information about the pages you visit and how you access and use the Campus Hub websites using cookies, tracking technologies and other third party analytics tools. Specifically, We and our service providers use cookies and similar technologies such as local storage (HTML5), web beacons, Javascript, and eTags on our websites. This information includes information about the devices you use to access the Campus Hub website including unique device identifiers, IP address, operating system, browser, and cookies. Depending on your device settings, we may also collect information about your geographical location and what websites you may travel from to our website. We use this information to better understand our customers and users, so that we may provide more effective advertising and products. You can learn about our use of cookies, and set your preferences, in our Cookie Statement.


Information from third parties.

We may supplement the information we collect with information from the Campus Hub affiliates and other third parties that we use to promote our products and services. For example, we may receive information from a third party about how well an online marketing or email campaign performed, or from conference and trade show organizers.


How We Use This Information
We use the information collected to provide and improve our website services and our products and to analyze usage information for sales and marketing purposes. We also use the information collected to communicate with you in any manner that you have requested. This analysis is necessary to further our legitimate interest in understanding our users and their interactions with us and our websites to best iterate and improve on our websites and communications, including marketing purposes, and to provide you with content that you have requested.Third party information that we collect from social media may be used to provide you with requested information or our newsletter or contact you regarding our services, opportunities, products, and/or events.


How We Share This Information
Where we use third-party analytics tools to help us understand how the Campus Hub websites are used, these parties will have access to some of your personal information. This includes analytics tools such as Google Analytics. We also share information with our vendors and service providers and other third parties for legal or business purposes, but only as permitted and subject to required limitations. See

Vendors, Partners, & Other Disclosures.


B. Customers (Schools and School Districts).
If you are a customer of Campus Hub, we are providing our products and services directly to your school or school district and we are a “data controller” for purposes of the personal information collected in connection with the customer accounts.


Information We Collect Directly from you.

We collect information necessary to provide the educational technology services as directed by you. The information collected from you depends on the specific product and what is needed to integrate with your systems and to set up and maintain accounts. This includes information in the following data categories:
Account information: The exact elements will depend on the product and what specific information you as a customer provide us, but often we receive from you include pupil records of students and parents of students enrolled in your school or district, such as directory information, email addresses, student IDs, account credentials, courses students are enrolled in, health information kept in student records, and other pertinent student information.


We also collect employee account information including but not limited to user names, email addresses and titles to initially set up products and services for you.


Indirectly from you.

We collect device and usage information when you access and use our products and services, including information that your browser or the mobile app sends when you are using it. This data may include your unique device identifier, IP address, your browser type and configuration, the date and time of your use of the product or service and cookie data. Specifically, we and our service providers use cookies and similar technologies such as local storage (HTML5), web beacons, Javascript, and eTags. The purpose of collecting such information is for improvement of our products and services to better meet the needs of our customers and their users. 
From third parties. We may receive information from affiliates in our Campus Hub of companies and other third parties. For example, we may receive limited personal information from third-party services that integrate with or complement the Campus Hub products or services in order to provide you with the best possible user experience.
How We Use This Information
We use your information to provide you the features and functionality of the Campus Hub products and services, as well as to communicate directly with you and allow you to communicate with other Campus Hub users. It is necessary for us to use your information in this manner in order to provide you with the services your school district has requested pursuant to its agreement with Campus Hub.We will use your information to provide you with news and information about new products and services. Any such marketing communications from us may be discontinued at any time. See Marketing. We may also use de-identified and aggregated information to understand and improve our products and services. We may share general customer contact information with certain Partners as is necessary to offer and provide our products and services to our current and prospective clients. No customer data other than general institution contact information is provided for these purposes. For absolute clarity, we do not provide any student data or personally identifiable information to any Partners for marketing purposes.


How We Share This Information
We share information to provide the Campus Hub products and services to you and further improve them. Within Campus Hub, your information will be accessed only by those who have a need to provide the Campus Hub products and services. We use vendors to help us provide the Campus Hub products and services to your school or school district. For example, if your school or school district has a hosted Campus Hub product or service, Wix and its partners provide our web and cloud hosting facilities. Third-party analytics tools may also have access to your personal information to help us understand how the Campus Hub products and services are being used. 


Student and School Employee Personal Information
Campus Hub is a data processor with respect to student and school employee personal information and the Campus Hub customer (school or school district) is the data controller. Where a Campus Hub customer enters into an agreement with Campus Hub to provide products and services, that Campus Hub customer acknowledges that Campus Hub is a data processor with respect to personal information received from that Campus Hub customer or from a student/parent or school employee in connection with the Campus Hub products and services.
Student and Employee Personal Data Ownership All student and school employee personal data remains the property of and is solely owned, and thereby controlled, by our Campus Hub customers. You grant Campus Hub a non-exclusive, royalty free license, to use equipment, software, your data or other material of yours solely for the purpose of providing, maintaining, and supporting you and other licensees with Campus Hub products and services.Campus Hub will only use student and school employee personal data for the purposes of providing the products and services that our customers (school or school districts) have contracted with us to provide and we will process student personal data according to instructions and the terms of our contract with our customers.Student and school employee personal data will not be used for targeted Advertising by Campus Hub or any of its affiliates.


C. Parents and Students
The school or school district decides how your personal information is used.
Campus Hub provides learning and registration products and services to end-users of a school or school district (our customers) as a “data processor.” The main responsibility of what is known as a “data controller” lies with the school or school district. This also means that the school or school district’s own privacy statement governs the use of student personal information. Campus Hub’s customers determine what information we collect through the Campus Hub products and services and how it is used, and we process that information according to our customer’s instructions and the terms of our contract with our customer.


This section of our Privacy Statement is provided for informational purposes and describes how parent and student personal information is used when Campus Hub products and services are provided through a school or school district. How that information is used depends on the school or school district, so please consult your institution’s privacy statement.


D. Users of our Products, not including Students or Parents.
The main responsibility of what is known as a “data controller” lies with the customer. This also means that the customer’s own privacy statement governs the use of personal information collected through our products. Campus Hub’s customers determine what information we collect through the Campus Hub products and services and how it is used, and we process that information according to our customer’s instructions and the terms of our contract with our customer.


This section of our Privacy Statement is provided for informational purposes and describes how applicant personal information is used when Campus Hub products and services are provided through a school or school district. How that information is used depends on the school or school district, so please consult your institution’s privacy statement.


E. Sharing with Vendors, Partners, and Other Disclosures
Vendors. We engage directly with certain third-party companies to help us provide the Campus Hub products and services to our customers or to you or to perform work on our behalf (“Vendors”). Our vendors are required to abide by our privacy and security instructions and are contractually restricted from using any personal information they access or receive from us for any purposes other than as needed to perform such services. We may use vendors to help us conduct marketing campaigns or events and disclose customer contact information necessary for those activities.


Other Types of Disclosures.

We may also share your information where required under the following circumstances:
Where permitted by applicable law and by contracts with our customers, we may disclose your information in the course of a corporate transaction such as a merger, acquisition, sale of assets, or a financing, or pursuant to a bankruptcy, dissolution proceeding or reorganization.


We may need to disclose your information to comply with legal or regulatory requirements and to respond to lawful requests, court orders, and legal processes. Where such disclosures relate to personal data we hold as a data processor on behalf of our customers, we will refer such requests to our customers where permissible.


We may need to disclose your information to protect and defend the rights, property, or safety of Campus Hub, our customers, or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or other misuse of our systems.
We may utilize aggregated or de-identified (anonymized) information that is no longer associated with a person to enhance and promote the Campus Hub products and services. Campus Hub does not rent, sell, or otherwise provide access to student or school employee personal data to third parties for marketing or advertising purposes.


Marketing.

We conduct marketing to promote the Campus Hub products and services, but do not use or disclose information (whether personal information or otherwise) about students that we collect through the provision of Campus Hub products and services for targeting of advertisements to students.When we conduct (or sponsor) events, conferences, and webinars, we will collect information about attendees, such as the session they attend and their contact information to provide them information about Campus Hub products and services and other Campus Hub information.


Marketing Preferences and Opt-Out.

Our marketing emails will always include an “unsubscribe” link so that you can change your preferences and opt-out of receiving marketing emails or communications from Campus Hub. You can also send us email at noreply@campushubspot.com to unsubscribe.Please note that even if you opt-out of marketing emails, we may still need to contact you with important information about your Campus Hub account.
Interest-based Advertising. We use third party advertising tools to collect information about your visits to the Campus Hub websites to provide targeted advertisements to you based on your browsing history on other websites or on other devices you may use. If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests.To learn more or opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit:


Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http://optout.aboutads.info/) and mobile application-based “AppChoices” download page (https://youradchoices.com/appchoices)
European Interactive Digital Advertising Alliiance (EDAA)’s consumer opt-out page (http://youronlinechoices.eu)
Network Advertising Initiative (NAI)’s self-regulatory opt-out page (http://optout.networkadvertising.org/).
Google Analytics and Advertising. We also use Google Analytics and other third-party cookies to collect certain information about your visits to our Campus Hub websites.  You can opt-out of third-party cookies from Google Analytics using the Google Analytics opt-out browser setting add-on or other ad management tools.


“Do Not Track” Signals. Without a common industry or legal standard for interpreting so-called “Do Not Track” (DNT) signals, Campus Hub does not respond to browser DNT signals.  We will continue to monitor further development of a DNT standard by the privacy community and industry.


III. Data Retention
A. Website Users
We keep website usage information for as long as necessary for the purposes described above. Account information is retained until you delete the account and for a limited period thereafter. Where you have provided information in forms, we retain the information as long as it is required, depending on the nature of the request. If you unsubscribe from receiving marketing communications from us, we will keep a record of this to ensure that you do not receive such communications in the future.


B. Customers (Schools and School Districts)
We keep information collected on behalf of our customers for as long as necessary and pursuant to contractual terms. We dispose of information that is not held pursuant to contractual terms in a commercially reasonable time period or at the request of a customer.
 
IX. Your California Privacy Rights
If you are a California resident, California Civil Code Section 1798.83 allows you to request information on how we disclose personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. You may make one request each year by emailing us at beth@campushubspot.com or writing to us (see address below in “CONTACT US”).


X. Links to Other Sites
Our Campus Hub websites may provide links to third party websites or resources. The information practices of those websites are not covered by this Privacy Statement or any other policies or terms applicable to the Campus Hub websites or the Campus Hub products or services. We recommend that you review any terms of use and privacy policy of any linked third party website before providing any information.


XI. Changes to This Privacy Statement
We may update this Privacy Statement and its last updated date to reflect changes to our data governance practices. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.


XII. For U.S. Educational Agency Customers
Pursuant to state law, the following state specific language is hereby incorporated into this Privacy Statement, provided that Campus Hub is providing and/or offering you Campus Hub products or services in one of the following states (capitalized terms below which are not otherwise defined in this Privacy Statement are as defined either in the applicable state law or in your Campus Hub agreement):


California – Campus Hub will not use your data for any purpose beyond the indicated purposes in the Terms of Use, which includes this Privacy Statement. This includes, but is not limited to, Campus Hub’s policy to never use PII from a Pupil’s Records to engage in targeted advertising.


Colorado – Campus Hub will not use your data for any purpose beyond the indicated purposes in the Terms of Use, which includes this Privacy Statement. Only the Campus Hub employees that have a legitimate interest in accessing your data, will be granted authorization by Campus Hub.


Connecticut – Campus Hub will not use your data for any purpose beyond the indicated purposes in the Terms of Use, which includes this Privacy Statement. This includes, but is not limited to, Campus Hub’s policy to never use any student’s PII to engage in targeted advertising. Campus Hub also avers to utilize industry standard security, or better, to ensure the protection of said student PII. Connecticut law shall govern this agreement between you and Campus Hub. All terms herein are defined in accordance with Public Act No. 16-189, and in case of any ambiguity or conflict between the terms herein and Public Act No. 16-189, then Public Act No. 16-189 will govern.


Florida – Campus Hub will provide notification of a security breach pursuant to requirements as mandated in the Florida Information Protection Act of 2014.


Maryland – Campus Hub will not use Covered Information to engage in targeted advertising.


New York – In accordance with New York Education Law § 2-d, Campus Hub will comply with and attach to your contract the Parents’ Bill of Rights for Data Privacy and Security, as applicable.


Pennsylvania – Campus Hub will provide notification of a security breach pursuant to the requirements of Pennsylvania’s Breach of Personal Information Notification Act.


Washington – Campus Hub will provide notice before making material changes to this Privacy Statement.
XIV.

 

Contact Us
If you have any questions or concerns about your privacy or this Privacy Statement, please Contact Us at beth@campushubspot.com
You may also write to us at:
Campu Hub LLC
530 S Gordon St
Nauvoo, IL 62354
 

2020 by Campus Hub.