Camp Privacy Policy

General Privacy Policy Matters

At Camp, we take the privacy of our users very seriously. This Privacy Policy is a part of our Terms of Service and it describes our policies on the collection, use, and disclosure of information that identifies, describes, relates to or is reasonably capable of being associated with you, your household or device (“Personal Data”) in connection with your use of the services and products offered through our websites, emails and mobile applications (collectively, the “Site”). Personal Data does not include publicly available information from government records, deidentified or aggregated consumer information, or information excluded from the scope of applicable data privacy laws, such as the General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA). The terms “we”, “us”, “our” and “Camp” refer to Camp NYC, Inc. When you use the Site, you consent to our collection, use, and disclosure of information about you, including information that may be considered Personal Data, as described in this Privacy Policy. We may modify this Privacy Policy from time to time in our sole discretion, and will post the effective date of any version of this Privacy Policy at the end of this Privacy Policy. By continuing to use the Site, you agree and accept the version of this Privacy Policy in effect at that time

1. Information We Collect from All Visitors

1.1 Categories of Personal Data Collected. We have collected and stored the following categories of Personal Data from or about you over the past 12 months:

Category	Examples	Collected?
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories	Yes
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Yes
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	Yes
G. Geolocation data.	Physical location or movements.	Yes
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment-related information.	Current or past job history or performance evaluations.	No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

1.2 When We Collect Personal Data. We collect Personal Data:

We collect and store information from or about you:

(a) when you directly provide it to us. This happens when you:
- (i) register or create an account;
- (ii) purchase or sell services or products (including at no cost), such as merchandise and registrations for activities, parties and celebrations – including the products or services purchased or sold, your payment information and your billing address;
- (iii) interact with or request assistance from our customer and user support team;
- (iv) complete contact forms, request newsletters or other information, or participate in contests and surveys; and
- (v) otherwise participate in any other activities we promote.
(b) automatically, when you use and interact with the Site.
- (i) your general activity on the Site;
- (ii) anonymized session identifiers;
- (iii) your geographic location. We use this data to provide you with location-based services (such as advertising and personalized content). Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings;
- (iv) website traffic volume, frequency of visits, and type and time of transactions you initiate through the Site;
- (v) information regarding your interaction with email messages (e.g., whether you opened, clicked on, or forwarded an email message);
- (vi) your Internet Protocol (IP) address;
- (vii) the type and settings of the device, operating system, and browser used to access the Site; and
- (viii) other information gathered through cookies and similar technologies, which are discussed further in the fourth section of this Privacy Policy, entitled “Cookies and Similar Technologies”.
(c) from other sources, as we may also receive information about you from our service providers and business partners, including companies that assist with payment processing, analytics, data processing and management, account management, hosting, user and technical support, and other services which we use to personalize your Site experience.

How We Use Your Information

We use information about you for several general purposes:

(a) to operate, maintain, and optimize the Site and your account;
(b) improve the quality and types of services that we deliver;
(c) to diagnose problems with and identify any security risks, errors, or needed enhancements to the Site;
(d) to provide you with technical support;
(e) to contact you for feedback or conduct research about Camp's customer and user base or Site;
(f) to provide you with information regarding our products and services;
(g) to process payments and provide you with the services you've paid for or requested;
(h) to notify you of technical updates or changes in policy;
(i) to process contests, sweepstakes, or other promotions and fulfill any related awards or discounts;
(j) to understand and analyze how you use our services and what products and services are most relevant to you;
(k) to collect aggregate statistics about use of the Site; and
(l) to analyze and develop our marketing strategy.

3. Cookies

3.1 What are Cookies?

Cookies are small text files that are placed on your computer by websites that you visit. These text files can be read by these websites and help to identify you when you return to a website. Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your computer when you have gone offline, while session cookies are deleted as soon as you close your web browser. To find out more about cookies, including how to see what cookies have been set and how to block and delete cookies, please visithttp://www.aboutcookies.org.

3.2 Other Technologies:

(a) We use cookies and similar technologies (such as action tags, also known as beacons, or pixels tags) for a number of purposes, including to remember preferences, track conversions, conduct marketing and promotional efforts, analyze site traffic and trends, and generally understand the online behaviors and interests of people who interact with our Site.

(b) We may use third-party advertising companies to serve advertisements on our behalf. These companies may use a cookie or an action tag to tailor the advertisements you see on this Site and other sites, to track your response to their advertisement, to determine whether advertising has been served and to measure the effectiveness of their advertising.

(c) We use third-party analytics service providers to assist us in collecting and understanding website usage information. We use information from these services to help us improve our Site and the services we provide to our users.

(d) By using the Site, you agree to our use of these tracking technologies.

4. Sharing Generally

4.1 Sharing of Personal Data. We may share information about you with the following third parties or in the following contexts:

(a) Service Providers: We work with other companies, agents and contractors (“Service Providers”) to perform services on our behalf. These Service Providers will have access to your Personal Data and other information to provide services associated with the Site, including to provide measurement and analytic services. These Service Providers are subject to strict data processing terms and conditions and are prohibited from utilizing, sharing or retaining your Personal Data for any purpose other than as they have been specifically contracted for (or without your consent).
(b) Advertisers: We may allow advertisers and associated third parties to collect and use information they need to ensure their ads are properly served and to measure the success of their campaigns on websites and apps.
(c) Corporate Affiliates: We may share information with our corporate affiliates, parents and/or subsidiaries.
(d) Others With Your Consent. We may ask for your explicit consent to share certain information with third parties.
(e) Pursuant to an Investigation: We may investigate and disclose information from or about you if we have a good faith belief that such investigation or disclosure (a) is reasonably necessary to comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on us; (b) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the Site; or (c) protects our rights, reputation, property, or that of our users, affiliates, or the public.
(f) Pursuant to a Business Transfer: We may share information from or about you with our parent companies, subsidiaries, joint ventures, or other companies under common control, in which case we will require them to honor this Privacy Policy. If another company acquires Camp or all or substantially all of our assets, that company will possess the same information, and will assume the rights and obligations with respect to that information as described in this Privacy Policy.
(g) As Anonymized Data: We may aggregate or de-identify Personal Data in a way that makes it impracticable to use that data to identify a particular person; we also sometimes maintain individual data records with personal identifiers removed. In this Privacy Policy, we refer to such data as “Anonymized Data” and do not consider it to be Personal Data. We may use Anonymized Data in order to create statistical information regarding the Site and its use, which we may then share with third parties. Though it is impracticable for third parties to use Anonymized Data to identify a particular person, it is possible. Further, we have explained in other sections of this Privacy Policy that in combination with supplemental data taken from other sources, third parties may be able to reidentify you. By using the Site, you understand and acknowledge this risk.

If you have any questions related to our use of third party service providers and their collection and use practices, please contact us at legal@camp.com.

4.2 Disclosures of Personal Data for a Business Purpose. In the past 12 months, we have disclosed the following categories of your Personal Data to the third parties described in Section 4.1:

(a) Identifiers.
(b) California Customer Records Personal Information Categories.
(c) Protected Classification Characteristics under California or Federal Law.
(d) Commercial Information.
(e) Internet or Other Similar Network Activity.
(f) Geolocation Data.

4.3 Sales of Personal Data. In the past 12 months, we have disclosed the following categories of Personal Data to the third parties described in Section 4.1:

(a) Identifiers.
(b) California Customer Records Personal Information Categories.
(c) Protected Classification Characteristics under California or Federal Law.
(d) Commercial Information.
(e) Internet or Other Similar Network Activity.
(f) Geolocation Data.

5. Social Media Features and Widgets.

Our Site may integrate with social sharing features or other related tools which let you share actions you take on our Site with other apps, sites or media, and vice versa. These features may enable the sharing of information with your friends or the public, depending on the settings you establish with the social sharing site. For example, you may click on a Facebook “like” button, which publishes to your Facebook account that you “like” one of the pictures or profiles featured on the Site. These features may also collect your IP address and which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Your interaction with these features are governed by the privacy policy of the relevant social sharing site. Please refer to the privacy policies of those social sharing sites for more information. As stated below, we cannot control Site visitors' and users' use of any such information or content you choose to make available publicly.

6. “Do Not Track” Signals

Please note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. The Site does not alter its practices when it receives a “Do Not Track” from a visitor’s browser.

7. Controlling Your Personal Data

Other users may be able to identify you, or associate you with your account, if you include Personal Data in the content you post publicly. We are not responsible for, and this Privacy Policy does not apply to, information you choose to post publicly.

Please note that the Site may contain links to unaffiliated third-party sites. Except as set forth herein, we do not share your Personal Data with them, and are not responsible for their privacy practices. We suggest you read the privacy policies on or applicable to all such third-party Sites.

If you join our email list, you can unsubscribe at any time by following the instructions provided within those emails.

To control cookies, you can modify your settings in most web browsers to accept or deny cookies or to request your permission each time a site attempts to set a cookie. You can also manually delete previously stored cookies at any time. Please note that if you choose to block cookies, doing so may impair the Site or prevent certain elements of it from functioning.

8. Data Retention and Account Termination

We will not retain any Personal Data from users who do not create a user account. After creating a user account, you can request to close your user account from within your user account. We will remove your account registration, but we may retain information about you for the purposes authorized under this Privacy Policy, unless prohibited by law. The time-period for which we keep information varies according to the information’s use. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need.

9. Children; United States of America

Camp is committed to protecting the privacy of children who use our site. Children under 13 are not permitted to create a user account. We do not knowingly collect Personal Data from children under 13. If you become aware that a child has provided us with Personal Data, please contact us (see “Contact Information”). If we become aware that a child under 13 has provided us with Personal Data, we will remove such information and terminate the applicable account. The Site is directed to users located within the United States of America only. Do not use this Site if you are not located in the United States of America.

10. Security

We use commercially reasonable efforts to follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect information about you, we cannot guarantee its absolute security.

11. Location of Data and Transfers of Information

We primarily store information about you, including Personal Data, on servers located and operated within the United States. If you reside outside of the United States we will store your Personal Data in the United States in order to provide and operate the Site. Therefore, our collection and use of your Personal Data is subject to the United States’ laws related to privacy and use of Personal Data and information. These laws, including what is determined to be “Personal Data and/or information,” may be less protective than those applicable to you in your country of residence. By accepting the terms of this Privacy Policy, you acknowledge, agree and consent to (1) the transfer to and processing of Personal Data on servers located outside of the country where you reside, (2) our collection and use of your Personal Data as described herein and in accordance with the laws of the United States that may be different and may be less protective than those in your country and (3) that you are taking a risk by using the Site.

12. Your California Privacy Rights

12.1 California's Shine a Light Law. California Civil Code Section § 1798.83 permits California residents that are users of our Site to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an e-mail tolegal@camp.com.

12.2 Deletion Rights. As a user of our Site and California resident, you may request that we delete the Personal Data we have collected from you. Once we receive and confirm your verifiable request in accordance with the procedures described in Section 12.6, we will either: (a) confirm the deletion of your Personal Data and direct any service providers to delete the same; or (b) reject the deletion and provide you with the reason for such rejection. We may reject your deletion request if retaining your Personal Data is necessary for us or our service providers to: (i) complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (iii) debug products to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (v) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); (vi) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent; (vii) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (viii) comply with a legal obligation; (ix) make other internal and lawful uses of that information that are compatible with the context in which you provided it; or (x) your request is for B2B Personal Data.

12.3 Access and Data Portability Rights. As a user of our Site and California resident, you may request that we provide you with access to Personal Data that we have collected over the past 12 months. Once we receive and confirm your verifiable request in accordance with the procedures described in Section 12.6, we will provide you with the: (a) categories of Personal Data we have collected about you;
(b) categories of sources for the Personal Data we have collected about you;
(c) business purposes for collecting or selling your Personal Data;
(d) categories of third parties of which we share your Personal Data;
(e) specific pieces of Personal Data collected about you in a readily useable format; and
(f) if we sold or disclosed your personal information for a business purpose, both
(i) the sale itself; and
(ii) the business purpose for such sale.

12.4 Personal Data Sales Rights.
(a) Opting-Out of Personal Data Sales
(i) If you are a (i) user of our Site, (ii) a California resident, and (iii) over the age of 16, you may request that we do not sell your Personal Data at any time. To exercise this right, you may opt-out by submitting a request to us at https://camp.com/data-requests/new.
(ii) If you opt-out of the sale of Personal Data using the link above, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months. However, you may opt-in to the sale by submitting a request to us at https://camp.com/data-requests/new.
(b) Opting-In to Personal Data Sales
(i) We will not sell Personal Data of our users if we know they are under the age of 16 unless we receive an affirmative authorization from such user if the user is over the age of 13 but not yet 16. If you are (i) a user of our Site, (ii) a California resident, and (iii) between the ages of 13 and 16, you may affirmatively opt-in to the sale of your Personal Data by submitting a request to us at https://camp.com/data-requests/new.
(ii) If you are (i) a user of our Site, (ii) a California resident, and (iii) under the age of 13, your parent or guardian may affirmatively opt-in to the sale of your Personal Data by submitting a request to us at https://camp.com/data-requests/new.
(iii) If you opt-in to the sale of Personal Data using the link above, you may opt-out to future sales by submitting a request to us at https://camp.com/data-requests/new.

12.5 Non-Discrimination Rights. (a) Non-Discrimination. If you exercise your rights under the CCPA as described in Sections 12.2 – 12.4, we will not:
(i) Deny you goods or services;
(ii) Charge you different prices or rates for goods or services;
(iii) Provide you a different level or quality of goods or services; or
(iv) Suggest that you may receive a different price or quality of goods and services for exercising such rights.

12.6 Exercising Your Rights. If you are a user of our Site and a California resident, you may submit a verifiable consumer request to exercise your rights hereunder pursuant to this Section 12 by either: (a) emailing us at legal@camp.com; or (b) https://camp.com/data-requests/new. Your request must provide enough information for us to reasonably verify: (i) you are either (1) the person whose Personal Data we have collected, or (2) an authorized representative of the person whose Personal Data we have collected; and (ii) the rights you are asserting in your request. We will try our best to respond to your request within 45 days. If we require more time to process your request, we will inform you of the reason why via email or mail, depending on the method you select when making your request. For clarity, any disclosures made by us shall only cover our Personal Data and the 12 month period preceding your request.

13. Modifications to this Privacy Policy

We may occasionally update this Privacy Policy. You can see when it was last updated by looking at the effective date at the bottom of this page. If you have a registered account, and the Privacy Policy has been modified since you last logged into your account, upon logging into your account you will be notified of the version of the Privacy Policy in effect at that time. Your continued use of the website after a revision to the Privacy Policy indicates your acceptance and agreement to the current Privacy Policy. We recommend that you periodically review the Privacy Policy to make sure you understand and are up-to-date on the information we collect and what we do with it.

14. Kids Privacy Assured by PRIVO: COPPA Safe Harbor Certification

Camp NYC, Inc. is a member of the PRIVO Kids Privacy Assured COPPA safe harbor certification Program (“the Program”). The Program certification applies to the digital properties listed on the certification page that is viewable by clicking on the PRIVO Seal. PRIVO is an independent, third-party organization committed to safeguarding children's personal information collected online. The PRIVO COPPA safe harbor certification Seal posted on this page indicates Camp NYC, Inc. has established COPPA compliant privacy practices and has agreed to submit to PRIVO's oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at 917-310-2425 or legal@camp.com. If you have further concerns after you have contacted us, you can contact PRIVO directly at privacy@privo.com.

15. Contact Information

If you have any further questions regarding our privacy practices or information about you, please feel free to contact us:

By mail at CAMP, Attention Legal Dept, 91 Fifth Ave, 4th Floor, New York, NY 10003
By email at legal@camp.com
By phone at 917-310-2425