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CAMP DIGITAL PRIVACY POLICY

1.0 BACKGROUND

Home & Local Services LLC, D.B.A CAMP Digital (“CAMP,” “we,” “us,” or “our”), is a digital advertising agency that develops and operates an on-line Capacity Managed Marketing (CMM) platform which supports our online marketing tools, website hosting on behalf of our clients and the services to support those activities. CAMP collects specific types of customer data to enable these services and to create optimal Customer Experiences (CX) across our CMM platforms and hosted websites. CAMP considers personal data to be anything that can or could be used to identify an individual or individual’s online activity either directly or indirectly.

CAMP is committed to collecting only that data which is necessary and securing all processed and stored data to safeguard our clients and their customers’ privacy and sensitive data. Collectively, we refer to our offerings, which encompass our in-person services, hosted websites, and telephone assistance, as our “services.” A client’s utilization of the Services implies their consent to the gathering and utilization of data as stipulated in this policy. 

2.0 SCOPE

All CAMP staff (i.e. Ownership, Executive Leadership, and personnel in every department) are responsible for executing this policy and immediately reporting any actual or suspected violations to the Privacy and Compliance Manager. 

This policy explains what data CAMP collects, how the data is used (processed, stored, and shared), how the data is protected, and customers’ rights relating to their personal data. This policy describes the lawful basis for collecting, processing, and sharing data subjects’ personal information and provides relevant contact details. 

This policy is designed to meet the legal obligations under the Privacy Shield Data Protection Act 2018 (DPA) and California Consumer Privacy Act (CCPA). 

3.0 INFORMATION WE COLLECT AND PROCESS

  1. Information You Provide

CAMP  will securely collect, process, use, store, and transfer the following categories of personal and engagement data to enable optimal operations, meet regulatory requirements, and continuously improve our products, services, and CX: 

  • Account Registration – When you register for an Account, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number.
  • Payment Information – When you add your financial account information to your Account, that information is directed to our third-party payment processor. We do not store your financial account information on our systems; however, we have access to, and may retain, subscriber information through our third-party payment processor.
  • Personal Data – This means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a user in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. “Personal Data” includes equivalent terms in other Data Protection Law, such as the CCPA-defined term “Personal Information,” as context requires.
  • Communications – If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. We may also receive a confirmation when you open an email from us.

 

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

  1. Information We Collect When You Use Our Services
  • Usage of our Services – When you use our Services, we may collect information about your engagement with and utilization of our Services, such as processor and memory usage, storage capacity, navigation of our Services, and system-level metrics. We use this data to operate the Services, maintain and improve the performance and utilization of the Services, develop new features, protect the security and safety of our Services and our customers, and provide customer support. We also use this data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business.
  • Client Website Usage Data – When Individuals or organizations submit data to our services through client hosted websites we may collect additional analytics information to help clients better understand how their websites are being engaged
    • Device Information – Information may include type of device, operating system, location of the device (if location services is enabled on the device), unique application identifiers and device settings 
    • Lead submission – We may collect on the behalf of Clients incoming contact information 
  • Service information & Metadata
  • Log Data – This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
  1. Information We Receive from Third Parties
  • Third-Party Accounts – If you choose to link our Services to a third-party account we will receive information about that account, such as your authentication token from the third-party account, to authorize linking. If you wish to limit the information available to us, you should visit the privacy settings of your third-party accounts to learn about your options.

4.0 How We Use Information

  • Provide, operate, and maintain our Services;
  • Improve, personalize, and expand our Services;
  • Understand and analyze how you use our Services;
  • Develop new products, services, features, and functionality;
  • Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the Service, and for marketing and promotional purposes;
  • Find and prevent fraud; and
  • For compliance purposes, including enforcing our Terms of Service, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

5.0 How We Share Information

We may share the information we collect in various ways, including the following:

  1. Vendors and Service Providers – We may share information with third-party vendors and service providers that provide services on our behalf, such as helping to provide our Services, for promotional and/or marketing purposes, and to provide you with information relevant to you such as product announcements, software updates, special offers, or other information.
  2. Aggregate Information – Where legally permissible, we may use and share information about users with our partners in aggregated or de-identified form that can’t reasonably be used to identify you.
  3. Third-Party Partners – We also share information about users with third-party partners in order to receive additional publicly available information about you.
  4. Analytics – We use analytics providers such as Google Analytics. Google Analytics uses cookies to collect non-identifying information. Google provides some additional privacy options regarding its Analytics cookies at http://www.google.com/policies/privacy/partners/.
  5. Business Transfers – Information may be disclosed and otherwise transferred to any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
  6. As Required By Law and Similar Disclosures – We may also share information to (i) satisfy any applicable law, regulation, legal process, or governmental request including requests made by public authorities to meet national security or law enforcement requirements; (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
  7. With Your Consent – We may share information with your consent. CAMP’s data sharing policy is to only share personal data when informed consent has been given by the data subject, sharing has been requested by the data subject, or it is required by law. Personal data will be protected from access by persons within CAMP unless expressly required for job-related functions as outlined in the user consent. 

6.0 PRIVACY AND SENSITIVE DATA PROCESSING SAFEGUARDS

In accordance with the processes and procedures outlined in CAMP ’s Information Security Policy (ISP), we proactively enable and continuously monitor a robust system of layered security controls specifically designed to limit and protect the collection, processing, storage and use of personal data. The following safeguards are designed to educate CAMP staff and users about our personal data collection, use, sharing, and protection. 

  • CAMP has defined a lean data scheme that minimizes data collection to that which is lawful and user-authorized for expressed purposes. 
  • Through direct and indirect collection, CAMP will verify data accuracy and encrypt stored data to promote the integrity of the data.
  • Prior to sharing personal data with outside parties, CAMP will obtain informed, active consent from data subjects for the data sharing. 
  • CAMP’s Privacy & Compliance Manager and executive leadership team oversees staff training on data protection standards. 
  • Our Chief Technology Officer (CTO) and Privacy & Compliance Manager implement and update systems configurations to enable the data protection policy, process, and procedures execution. 
  • Our Privacy & Compliance Manager manages all customer data-related questions, responses, complaints, and initial actual/potential compromise investigations. 
  • CAMP’s Privacy & Compliance Manager oversees data protection efforts, and can be reached via email: [email protected]

7.0 DATA RETENTION 

We retain personal data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).

When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

8.0 CUSTOMER RIGHTS AND RESPONSIBILITIES 

CAMP  has a legal obligation to protect customer data as a controller of personal data. For the customers’ part, data should be kept up-to-date, accurate, and secure from public disclosure or easy unauthorized access. Business customers should never share accounts, user IDs, or passwords, and passwords should be complex. 

Per CCPA and states with similar principles & regulations, residents have the right to: 

  • Know and have access to what personal data CAMP collects and uses,
  • Request correction of any incomplete or inaccurate data, 
  • Request erasure of personal data (subject to legal obligations that CAMP has in relation to data retention, of which the customer will be notified, if applicable, at the time of the request), 
  • Withdraw consent to the processing of their personal data (where a customer withdraws consent, CAMP may not be able to provide products or services to that customer),
  • CAMP  does not discriminate against users who exercise their rights under CCPA
  • Close their account.

Data subject access requests should be sent to ([email protected].) All requests will be fully responded to within 45 days, unless a request is particularly complex, or a significant number of requests have been made. CAMP may refuse to comply with a customer request in certain circumstances such as clearly unfounded, repetitive or excessive requests. As part of its handling of the requests, CAMP may need to contact the customer to confirm their identity to process the request. 

9.0 Children’s Policy

CAMP does not knowingly collect information from children under the age of 13, and children under 13 are prohibited from using our Services. If you are under the age of 13, you must ask you parent or guardian for permission to use this website

10.0 USE OF COOKIES

CAMP uses cookies to enable website features and customer experience (CX) by customizing each user’s interaction with site services and capabilities. Cookies are small files stored on the user’s computer designed to hold a modest amount of data specific to a client and website, which can be accessed either by the web server or the client computer. 

11.0 Changes to this Privacy Policy

This Privacy Policy may be modified from time to time, so please review it frequently. Changes to this Privacy Policy will be posted on our website.

Contact Us

If you have any questions or concerns about this Privacy Policy, please email us at write to us at: [email protected]

CAMP Digital

7505 Metro Boulevard, Suite 600

ATTN: Compliance

The data controller of your personal information is CAMP