Last Modified: September 5, 2019
2. Personal Information We Collect
When you interact with the App, we may collect personal information such as:
- First and last name;
- Email address;
- Phone number;
- Physical address;
- Postal address;
- IP address;
- Unique device ID or other online identifier;
- Location information, such as real-time information about the location of your device;
- Education information, such as school(s) attended, class schedule, year in school (e.g., freshman), and [expected] year of graduation; and
- Biographical information, such as personal interests and hometown.
We may also collect general information about the equipment you use to access the App, your operating system and browser type, the services that you use, times and dates of your interactions with the App, details of your transactions through and interactions with the App, and software event data.
3. How We Collect Information
We may collect information:
- Directly from you when you provide it, including by filling out forms, setting up an account and personal profile, participating in sweepstakes, contests, or promotions, or contacting us through our “Contact Us” or “Stay Updated” form.
- Automatically as you interact with the App, such as location data, data on browsing activities and patterns, times and dates of logins, and event data.
- From third parties, including analytics providers, that we use to operate the App and its services.
Web Beacons. Web beacons are small graphic images or other programming code (also known as “1×1 GIFS” or “clear GIFs”). We may include web beacons in the App pages and email messages. Web beacons may be used to count visitors to the App, to monitor how users navigate the App, and to count how many emails that we send are actually opened.
4. How We Use Your Personal Information
We may use or disclose your information for one or more of the following business purposes:
- Providing the services you’ve requested or agreed to receive.
- Enabling you to participate in App features.
- Enabling you to participate in sweepstakes, contests, and promotions through the App.
- Processing your account registration, including determining your eligibility for an account.
- Responding to your questions, feedback, or other requests.
- Improving and managing the App.
- Informing you about new features of the App.
- Notifying you regarding your use of the App, and changes to the App.
- Marketing our products and services to you and sending you marketing materials that may be of interest to you, but only if you consent to providing your information for this purpose.
- For any other purpose disclosed by us when you provide the information.
- For other purposes with your consent, which you may withdraw at any time.
Marketing Communications from College Town Insider LLC. We will send you marketing communications only with your express consent. If you choose not to consent, you may still access the App, but you may not receive important information about features and functionality of the App or other products that may interest you.
5. How We Share Information
Third Parties Providing Services on Our Behalf. We use third parties to host the App, design and operate the App features, and perform administrative, analytics, payment processing, advertising, and communications services. Services these parties provide include processing your payments made through the App, enabling us to send you email newsletters, displaying advertisements on the App, and providing information to us about the use of the App and viewing of our content. We may disclose your personal information to these companies so they can carry out these business purposes on our behalf. These companies are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. We may use: (a) third-party analytics service providers and (b) ad-serving platforms which may set and access their own cookies and web beacons on your device. These parties may have access to usage information.
Currently, we use the following two Google, Inc., services:
AdMob by Google
- AdMob is a mobile advertising service that helps us display advertisements in the mobile application. You can opt-out of the AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en. For more information on how Google uses the collected information, please visit the “How Google uses data when you use our partners’ sites or app” page: http://www.google.com/policies/privacy/partners/.
For more information on the privacy practices of Google more generally, visit the Google Privacy Terms web page: http://www.google.com/policies/privacy/.
- Heap automatically captures every web, mobile, and cloud interaction: clicks, submits, transactions, emails, and more to help us analyze user behavior. For more information on the privacy practices of these entities, visit their respective privacy policies at https://docs.heap.io/docs/data-privacy
- Fabric provides our development team the ability to monitor user behavior, app crashes, and deliver analytics about how users use the app. For more information on the privacy practices of these entities, visit their respective privacy policies at https://fabric.io/terms
Sweepstakes, Contests, and Promotions. We may offer sweepstakes, contests, and other promotions (each, a “Promotion”) through the App that may require registration. By participating in a Promotion, you agree to the terms, conditions and/or official rules that govern that Promotion. If you choose to enter a Promotion, we may disclose your personal information to third parties or the public in connection with the administration of the Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners’ list.
Administrative and Legal Reasons. We may also disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us; and (b) protect and defend our rights or property, the App, its users, or the public.
Business Transfer. We reserve the right to disclose and transfer all information related to the App, including, without limitation, your personal information, demographic information and usage information: (i) to a subsequent owner, co-owner, or operator of the App or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, without limitation, during the course of any due diligence process.
6. Sales of Personal Information.
We have not sold, and—except in connection with a business transfer (described above)—we will not sell your personal information.
7. Links to Other Websites and Services
Personal information is stored in secure operating environments that are not available to the public. In some instances, personal information is encrypted during storage and transmission. Only those of our employees and agents who need access to your personal information to do their jobs are allowed access, each having signed confidentiality agreements or otherwise subject to a duty of confidentiality.
While we make reasonable efforts to safeguard your personal information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. As a result, we cannot ensure or warrant the security of any information you transmit to us or information we transmit to you from the App, and you assume all related risks.
We regularly review the information that we collect and store. We retain your personal information until you request that we delete it. In certain cases, we may be required to continue to retain your data to comply with applicable law or in connection with a legal claim.
9. Other Information
Lawful Bases. We collect and process your personal information only when we have a lawful basis to do so. Lawful bases include your consent, the fulfillment of our contractual rights or obligations, complying with applicable law, and the legitimate interests of College Town Insider LLC or third parties (provided that processing your data for a legitimate interest does not outweigh your rights and freedoms). Examples of a legitimate interest include (i) analyzing user data to maintain and improve the App for all users; (ii) providing you with access to the App and its services; (iii) providing you with up-to-date information about new features of the App; (iv) engaging third-party providers to deliver certain features of the App; and (v) complying with record retention laws or other legal obligations. You may withdraw your consent or object to a legitimate interest at any time by contacting us at the information provided below.
Do Not Track. Some browsers incorporate a “Do Not Track” (DNT) feature that, when turned on, signals to websites and online services that you do not want to be tracked. At this time, the App does not respond to DNT signals.
Children Under 16. The App is not intended for children under 16, and we do not knowingly collect personal information from children under the age of 16. If you are under 16, please do not use the App or submit any personal information through the App.
If you have reason to believe that a child under the age of 16 has provided their personal information to us, please contact us, and we will delete that information.
10. Your Choices and Privacy Rights
If you choose not to provide personal information, you may be unable to access or use the App or certain App features. For example, not providing location information will cause the App’s location-based features to be disabled.
Your Privacy Rights. You may access and update the personal information you provided to set up your account at any time through your account. If you would like to obtain a copy of all personal information gathered by the App, terminate your account, or if you would like to correct or delete your information, you may submit a request to us through the mobile application’s Feedback feature (registered users only), or by email at firstname.lastname@example.org. Our response to your inquiry may include, as applicable:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
We cannot delete your personal information without also deleting your account. Please also note that personal information you provide through “Moments,” “Hives,” and “Events,” or through other interactive features of the App – such as by commenting or interacting with other users’ posts, or otherwise make available to other users, may continue to be retained by other users indefinitely and may be shared publicly by those users.
Depending on the law that applies where you live, you may have additional rights, such as the right to object to further processing of your personal information, the right to request restrictions on such processing, or request that we send your information to another organization of your choice (where technically feasible).
Please note that we may ask you to verify your identity before responding to any request. We will not discriminate against you for exercising your privacy rights.
Opting Out. If you no longer wish to receive promotional and marketing communications from us, send us an email at email@example.com. You can also stop receiving certain types of email communications from us by clicking on the “unsubscribe link” provided in such communications.
Improper Collection and Misuse of Personal Information. Please report any improper collection or misuse of personal information to firstname.lastname@example.org. Depending on the law where you live, you may also have the right to file a complaint with your local data protection authority.
11. Our Contact Information
College Town Insider LLC
185 Dartmouth Street, 7th Floor
Boston, MA 02116
Phone (Toll Free): (833)262-2899