UPPERCAMPUS’S PLATFORM PRIVACY STATEMENT FOR PUBLISHERS AND THEIR AUTHORIZED USERS
UpperCampus, Inc. (“UpperCampus”) provides its web-based platforms — Campus Portal for Schools and Employer Portal for Employers (each a “Platform,” and collectively the “Platforms”) — to academic institutions and companies (any, a “Publisher”). Our Platforms allow Publishers to showcase their respective academic institutions or companies, and deliver customized content to students who use the UpperCampus App. This UpperCampus Platform Privacy Statement for Publishers and their authorized users (“Privacy Statement”) explains how we collect, use, disclose and otherwise share personal information on our Publisher’s behalf in connection with use of the Platform by a Publisher’s employees, authorized users and others whom the Publisher authorizes to use the Platform (each, an authorized user). As a service provider, UpperCampus provides the Platform to Publishers. This means — for a Publisher’s authorized users’ personal information — Publishers control such personal information processed through the Platform.
Information We Collect
Information collected via the Platform. For the Platform, the Publisher is responsible for determining the scope of information that UpperCampus may collect about its authorized users.
Information collected about authorized users. We collect information about the Publisher’s authorized users, including its respective teachers, administrators, guidance counselors, Alumni Mentors, administrative and human resource personnel, contractors or others engaged for recruiting purposes. The Publisher has permitted these authorized users to create an account to access, view and contribute content to the Platform. The information we collect about authorized users may include:
Information provided to us by the Publisher about its authorized users. This may include business contact information, such as name, email address, and phone number.
Information provided to us by authorized users. This may include information that authorized users provide when they register for an account or create a user profile (such as name, email address, telephone number, high school, college, company, employer, profile image, username, access credentials, social media links, job description and job title), contact Publisher support, or otherwise correspond with us by phone, email, or other means.
Information submitted by the authorized users for posting within the Platform. This may include any customized content submitted through the services, such as text, images, audio and video (including metadata associated with such submissions).
Information about authorized users’ use of the Platform. This may include computer operating system type and version number, manufacturer and model, device identifier, browser type, screen resolution, IP address, general location information such as city, state or geographic area; and information about authorized users’ use of and actions on the Platform, such as pages viewed, how much time was spent on a page, navigation paths between pages, information about activity on a page, access times, and length of access. This information is collected using cookies and similar tracking technologies.
How We Use Information
We use the information that we collect at the instruction of the relevant Publisher and in accordance with the relevant Publisher agreement, to provide the Platform and for related internal purposes, such as:
To provide the services;
To provide information about the Platform, such as important updates or changes to the Platform;
To measure performance of and improve the Platform or our services and develop new products and services;
To create anonymous, aggregated or deidentified data that UpperCampus may then use to analyze patterns to enhance UpperCampus’s products and services and develop new ones; and
To respond to inquiries, complaints and requests for Publisher support.
We may also use information as we believe necessary or appropriate to (a) comply with applicable law; (b) enforce the terms and conditions that govern the Platform; (c) protect our rights, privacy, safety or property and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
How We Share Information
We share the information we collect:
With the relevant Publisher from which we obtained the information or for whom we collected the information;
With student users and others of the UpperCampus App;
With such third parties as the relevant Publisher may direct;
With third-party service providers that help us manage and improve the Platform; and
With professional advisors in the course of the services they provide to us.
We may also share information with government, law enforcement officials or private parties as required by law, when we believe such disclosure is necessary or appropriate to (a) comply with applicable law; (b) enforce the terms and conditions that govern the Platform; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
We may sell, transfer or otherwise share some or all of UpperCampus’s business or assets, including information that we process as part of the Platform, in connection with a business transaction (or potential business transaction) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy.
UpperCampus uses commercially reasonable physical, electronic, and procedural safeguards designed to protect information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction, in accordance with applicable law. We cannot, however, guarantee that any safeguards or security measures will be sufficient to prevent a security problem. We recommend that Publisher and its authorized users take steps to protect against unauthorized access to any devices or networks used to access the Platform. See the relevant Publisher agreement for additional information regarding UpperCampus’s information security practices.
Data Subject Rights, Do Not Track, and Age Limitations
The relevant Publisher is the data controller of its authorized users’ personal information processed through the Platform. As the data controller, the relevant Publisher is responsible for receiving and responding to authorized users’ requests to exercise any rights afforded to them under applicable data protection laws. UpperCampus will assist its Publishers in responding to such requests as set forth in the relevant Publisher agreement. Publisher shall be responsible for providing any privacy notices as required by law to any authorized users of the Platform.
Some Internet web browsers transmit “do not track” signals to the websites and other online services with which your web browser communicates. There is currently no standard that governs what, if anything, websites should do when they receive these signals. Currently, UpperCampus does not take action in response to these signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
UpperCampus does not allow use of the Platform by anyone younger than 18 years old. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact the relevant Publisher. We will take steps to delete such information from our files as soon as reasonably practicable. We encourage parents or guardians with concerns to first contact the relevant Publisher and then, if necessary, contact us.
Cross Border Data Transfer
UpperCampus may transfer information collected through the Platform outside of the country from which it originated, including to the United States. See the relevant Publisher agreement for additional information regarding how UpperCampus safeguards the information it transfers across borders.
UpperCampus may retain information for as long as necessary to (a) provide the Platform; (b) comply with legal obligations; (c) resolve disputes; and (d) enforce the terms of its Publisher agreements. See the relevant Publisher agreement for additional information regarding UpperCampus’s data retention practices.
Third Party Products and Services
The Platform may integrate with or enable access to third party tools. Authorized users that register, install or access any third party tools may be required to accept privacy notices provided by those third parties. Please review those notices carefully, as UpperCampus does not control and cannot be responsible for these providers’ privacy or information security practices.
Changes to this Privacy Statement
UpperCampus reserves the right to modify this Privacy Statement at any time. Similar to UpperCampus’s Platform, laws, regulations and industry standards may evolve which may make changes to this Privacy Statement appropriate. UpperCampus will post the changes to this page. UpperCampus encourages you to review the Privacy Statement to stay informed. In accordance with applicable law, UpperCampus will notify you of any material changes in its collection, use, or disclose of your information by posting a notice on its website. Any material changes to this Privacy Statement will be effective thirty (30) calendar days following notice of the changes on the website. These changes will be effective immediately for new users of the Platform. If you object to any such changes, you must notify UpperCampus prior to the effective date of such changes that you wish to deactivate your account. Continued use of the Platform following the effective date of such changes indicates your agreeing to such changes.
If you have any question about this Privacy Statement, you can contact our privacy team at .