Campwise Privacy Policy

PRIVACY POLICY

Last Modified: June 3, 2019
Effective Date: June 3, 2019

1.  Introduction.  RecSoft, LLC, a Virginia limited liability company (referred to in this Privacy Policy as “RecSoft”, “we”, “us”, or “our”) has developed a camp management solution for summer camps and conference centers known as “Campwise”, which includes features accessible through the website located at: https://cwngui.campwise.com (the “cwngui Website”). The Subscriber Website is made available for use only by the camps and conference centers (each, a “Subscriber”) that have purchased a subscription to Campwise and entered into a written agreement with RecSoft (a “Subscriber Agreement”) and by the authorized end users of such Subscribers, which may include parents of campers, summer staff, camp administrators, and donors.

2. Processing on Behalf of the Subscriber.  This Privacy Policy describes the types of information we may collect through your use of the Subscriber Website and our practices for collecting, using, maintaining, protecting, and sharing that information. The collection and processing of your Personal Information through the Subscriber Website is performed by RecSoft on behalf of the applicable Subscriber, and all of the information you provide or that is collected through your use of the Subscriber Website may be shared with the Subscriber. The Subscriber determines the types of Personal Information that are collected and how that information is processed, used, and shared by the Subscriber. We do not use your Personal Information for any purpose other than to process and store it on behalf of the applicable Subscriber. We encourage you to contact the Subscriber to obtain a copy of the Subscriber’s privacy policy to understand how your Personal Information is used and shared by the Subscriber. You should direct your privacy inquiries, including any requests to exercise any data protection rights, to the applicable Subscriber. This Privacy Policy does not apply to information that we collect, or is provided to us, separately from the Subscriber Website.

3. Updates to Privacy Policy.  As technology changes and as our business grows and develops, we may modify this Privacy Policy from time to time. Changes to this Privacy Policy will be made and will become effective as described in the Customer Agreement.

4. Children Under Age 13.  We are committed to protecting the privacy of children under the age of thirteen (13) years (each a “Child” and collectively, “Children”). The Subscriber Website is not designed for or marketed to Children, and we do not knowingly collect Personal Information (as defined below) from Children. If we learn we have collected or received Personal Information from a Child, we will delete that information.

5. Definitions.  As used in this Privacy Policy:

            5.1.  Financial Information” means credit or debit card numbers, card type, card issuer, expiration dates, CVV/CSV/CSC or other security code, bank account numbers, and routing numbers.

            5.2.  Personal Information” means personally-identifiable information (information relating to an individual that can be used to identify, locate, or contact that individual, alone or when combined with other personal or identifying information), such as: name, home or physical address, e-mail address, phone number, or personal characteristics, Sensitive Information (as defined below), or any other information about an individual that we collect through the Subscriber Website and maintain in personally identifiable form in combination with other personally-identifiable information.

            5.3.  Sensitive Information” means Social Security numbers, bank account numbers, credit or debit card numbers, insurance policy numbers, login or authentication credentials (such as passwords), or other similar information.

            5.4.  Non-Personal Information” means information or content other than Personal Information, including, for example, aggregated or anonymized information about our users and other information that does not identify any individual.

6.  Types of Information Collected.

            6.1.  Visitor Information.  We may automatically collect information about you when you use the Subscriber Website, such as the pages and other materials you access, the amount of data transferred, the links you click, the amount of time you spend interacting with each page, and other information about your interactions with the Subscriber Website, as well as certain standard information that your browser sends to every website that you visit, including your Internet Protocol (IP) address, operating environment (such as browser type and version, browser plugins installed, operating system version, regional and language settings, screen size and/or resolution, windows size, and page size), access dates and times, and referring websites. The Subscriber Website may use cookies, flash cookies, web beacons, and other technologies for a variety of purposes, such as saving and retrieving information about you, your visit, and assisting in displaying relevant promotions and advertising to you. We may use such technologies to share non-Personal Information with third parties or to retrieve Non-Personal Information from third parties. At this time, the Subscriber Website does not respond to “Do Not Track” signals sent to us by your browser.

            6.2.  Information You Provide.  The features that are available to you when you use the Subscriber Website is determined based upon the features purchased by the Subscriber who has authorized your use of the Subscriber Website and your relationship with the Subscriber (such as whether you are a staff member, donor, or parent of a camper). Depending on the choices made by the Subscriber, when you use the Subscriber Website, you may provide a wide variety of information through the Subscriber Website. In order to use most certain features of the Subscriber Website, you may choose to create an account (a “User Account”). When you create and use your User Account, you may provide us with a wide variety of information, such as your name, postal address, physical address, e-mail address, phone number, and other types of information. We will store and use such information only in accordance with this Privacy Policy and the applicable Subscriber Agreement.

7.  Use of Non-Personal Information.  We may use Non-Personal Information (including, for example, aggregated information about our users or information that does not identify any individual) for any purposes whatsoever (including without limitation, advertising, marketing, enhancing, designing, or developing products and/or services, and research), and we may share Non-Personal Information with others, including the Subscriber and our partners, affiliates, and our service providers.

8. Use of Personal Information.  

            8.1.  We will only store and use your Personal Information as is reasonably necessary or appropriate in connection with your use of the Subscriber Website, including: (a) to contact you in connection with your use of the Subscriber Website, including to respond to your inquiries; (b) for authentication and identification purposes; (c) to enable us to provide the features of the Subscriber Website; (d) to process your payments and to provide you with notices about your User Account and your payments; (e) to fulfill any other purpose for which you provide such information; (f) in any other manner as directed by the applicable Subscriber; (g) to carry out our obligations and enforce our rights; and (h) to protect our networks, data, software, or business interests. You understand and agree that we may transfer, process, maintain, and store your Personal Information and other information in any country (or in multiple countries), including countries other than your country of residence or the country or countries where you use the Subscriber Website.

            8.2.  We are committed to protecting your privacy and we will not sell, lease, or disclose your Personal Information to any third party, other than the applicable Subscriber, except as described in this Privacy Policy.

            8.3.  In addition to using and disclosing your Personal Information in the manner described above and elsewhere in this Privacy Policy, we may disclose your Personal Information:

                      8.3.1.  to any person, entity, or organization which you consent for us to disclose your Personal Information to;

                      8.3.2.  to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by us about our users is among the assets transferred;

                      8.3.3.  to any of RecSoft’s affiliates, our business partners, service providers, vendors, and agents who provide hosting services, technical support services, order processing services, payment processing services, and as is necessary or appropriate in connection with the processing of payments or the operation, maintenance, and support of the Subscriber Website;

                      8.3.4.  to any person, entity, or organization in order to facilitate the provision of the Subscriber Website or the processing of payments, such as providing your name, contact information, and payment information to our third party order and payment processor(s);

                      8.3.5.  to comply with any legal requirements, subpoenas, discovery requests, or court orders, to defend any legal or administrative proceedings, or as we believe in good faith is necessary to comply with any laws or legal requirements;

                      8.3.6.  as we believe is necessary or appropriate in an emergency situation, including without limitation, to prevent criminal activity, personal injury, or property damage;

                      8.3.7.  to law enforcement, financial institutions, or other appropriate authorities in connection with any investigation of suspected criminal or fraudulent activity by any person or entity; and

                      8.3.8.  if we believe it is necessary or appropriate to protect the rights, property, or safety of RecSoft, our Subscribers, users, customers, or other third parties.

9. Use of Personal Information.  We will store and use Personal Information only in accordance with this Privacy Policy and the Subscriber Agreement between RecSoft and the applicable Subscriber.

10.  Opt-In Sharing Features.  We will not knowingly disclose your Personal Information to a third party, other than the Subscriber, if we know or have reason to believe that the third party will use your Personal Information for direct marketing purposes.

11.  Payment Processing.  We currently use Ministry Brands LLC/CashLINQ Group LLC, d/b/a MinistryLINQ (“MinistryLINQ”), a third party payment processor, to process payments made through the Subscriber Website. Your Financial Information collected through the Subscriber Website is transmitted directly to MinistryLINQ and, except for the last four digits of credit or debit card numbers, card type, and card issuer, is not stored by RecSoft. You acknowledge and agree that we are not responsible for any acts or omissions of MinistryLINQ. The funds collected from payments processed through the Subscriber Website are transferred to the applicable Subscriber. Any questions, concerns, or refund requests should be directed to the Subscriber.

12.  Security.  We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure, including the use of TLS to encrypt information you send through the Subscriber Website. The safety and security of your information also depends on you. You are responsible for safeguarding username and password associated with your User Account and notifying us immediately if you suspect your username and password have been compromised. Unfortunately, the transmission of information via the Internet is not completely secure. Despite our measures to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to or through the Subscriber Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures of the Subscriber Website or of our Subscribers, service providers, agents, or other third parties.

13.  Third Party Sites.  The Subscriber Website may contain links to other websites that are operated by third parties (including the Subscriber). Once you have clicked on a link connecting you to such third party website, you will leave the Subscriber Website and be taken to a website that we do not control. This Privacy Policy does not apply to any Personal Information (or other information) collected on a third party site. We suggest you read the privacy policy of the third party site before providing any Personal Information on such third party site. We are not responsible for any use by any person or entity of any information that you may provide while accessing or using any websites or services provided by a third party.

14.  Access to and Change of Personal Information.  The Personal Information you provide through your use of the Subscriber Website is controlled by the Subscriber who has authorized your use of the Subscriber Website. To request access to, or correction of, such Personal Information, you must contact the applicable Subscriber.

15.  Contacting Us.  You may contact us with questions relating to this Privacy Policy by phone at 866-297-7111, by mail at 39 Southgate Ct. Suite 201, Harrisonburg, VA 22801, or by email at info@campwise.com.