Privacy Policy

Protecting your information is very important to CampusThreads Network Corp, registered in Canada, having its registered office address at PO BOX 30057 TORONTO RPO DOVERCOURT, ON M6J 3V3 (“our”, “us” or “we” or “CampusThreads”).

This Privacy Policy relates to services provided through our website at https://campusthreads.co (our “Website”) or using any of the services offered via the Website, such as CampusThreads Community, CampusThreads Chat or the CampusThreads widget on a customer website or the CampusThreads Mobile App (the “Platform”). You will be asked to indicate that you acknowledge and consent to the practices described in this Policy that set out the basis on which the Personal Data is collected from you, or that you provide to us will be processed by us.

Definitions

“Ambassador” means a person acting on behalf of a CampusThreads Customer as its representative and interacts with End Users.

“End User”  means any individual that has access to or engages with the CampusThreads Platform, including Customer Staff.

“Consumer” means any End User, website visitor or job applicant.

“Controller” has the meaning under the GDPR. Where indicated “Controller” also refers to a “Business” under the CCPA, CPRA, VCDPA, and other applicable USA state-specific legislation.

“Customer” means an entity that subscribes for a license to use the CampusThreads Platform.

“Customer Staff” means any employee or authorized representative of the Customer who has access to the CampusThreads Platform.

“Data Protection Laws” may include: Regulation: The Personal Information Protection and Electronic Documents Act (PIPEDA).

“Partner” means a third party that hosts the CampusThreads widget on their website or an entity that has an established commercial relationship with CampusThreads

“Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations (collectively the “Data Protection Laws”).

“CampusThreads Chat” means the product within the Platform that enables End Users to explore the university website which is embedded with Ambassadors and Customer Staff profiles on the university website to allow End Users to engage in communications with the University selected Ambassadors and Customer Staff.

Platform and Website Users

Where you are using your CampusThreads account or CampusThreads Platform directly, CampusThreads acts as the “Data Controller” of such personal Data or “Business” (as defined in The Personal Information Protection and Electronic Documents Act (PIPEDA) legislation) and for some of our products, we act as Joint Controller, together with the Customer as described below in the section titled “2. Information we collect about you”.

Where Customers jointly agree with CampusThreads to collect additional Personal Data in the creation of CampusThreads accounts, we may act as a Joint Controller, together with the Customer. Where this applies, this will be specifically agreed with Customers on a case by case basis and made clear to End Users.

Where users are accessing the Platform via the Customer (Ambassadors and other Customer Staff), the Customer acts as the Data Controller. CampusThreads shall process personal information as a Data Processor on behalf of the Customer, who uses our services (see “Information We Receive from Other Sources” below). For all respective occasions above we ensure that we comply with existing Data Protection Laws.

Job Applicants

In respect of Personal Data of individuals/consumers collected where you apply for a role at CampusThreads, we will be the Data Controller and certain aspects of this Policy will apply to our processing of your personal information.

Minimum User Age 

End Users must be at least 13 years old to use our Platform or such greater age as required in your country or territory to register for or use our Platform without parental approval. Some of our Platform features may only be available to users that are above 18 years old.  End Users may be required to submit their date of birth for age verification purposes. Where there is a justifiable reason to use the Platform below the relevant age of consent, parental consent will be required for such use.

How to contact us

If you wish to access an older version of our Privacy Policy, please contact us at team@campusthreads.co Please contact the Controller/Business party in the first instance to address your rights with respect to your data.

Please contact the Controller/Business party in the first instance to address your rights with respect to your data.

This policy (together with our Cookie Policy, Terms of Use and Acceptable Use Policy and any other documents referred to therein), sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by CampusThreads and supplements, where applicable, the Customer’s privacy policy.

How information is provided to us

You will be asked to provide us with your information when you:

• fill in forms on our Website, Platform, or correspond with us by phone, email or otherwise;
• register to use our Platform (creating a CampusThreads account);
• use the Platform;
• report a problem with our Platform; or
• complete any surveys we ask you to fill in (optional).

Where you enter any details relating to a Third party, you must have obtained clear permission from the individuals whose data you provide us with before sharing that data with us.

For the avoidance of any doubt, any reference in this Privacy Policy to your data shall include data about other individuals that you have provided us with.

Information we collect about you

CampusThreads acting as a Data Controller or Joint Controller

In respect of all End Users, with regard to each of your visits to our Website or use of the CampusThreads Platform, we may automatically collect the following information:

• device-specific information, such as your hardware model, operating system version, unique device identifiers, and mobile network information;
• technical information about your computer, including where available, your IP address, operating system and browser type, for system administration and analytical purposes; and
• details of your visits to our Website, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time), length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs), details of whether you are using the Website or the CampusThreads Platform.

Data Controller

In respect of End Users of the Platform we collect contact information set out below in the table in section 4 (HOW WE USE YOUR INFORMATION AND JUSTIFICATION OF USE). We work with our Customers to determine what Personal Data we will collect from End Users and how it will be used. We operate as either Data Processors of the Personal Data collected where the Customer is the Data Controller, or as Joint Controllers with our Customers in relation to the Personal Data as described in the next paragraph. For other processing activities and to the extent that we determine how the Personal Data should be used for the purposes set out in section 4, we are the Data Controller of the Personal Data.

Joint Controller

In addition, Customers may request and agree with CampusThreads to collect certain additional Personal Data from End Users, in which case CampusThreads acts as a Joint Controller of such Personal Data. Such Personal Data may include but is not limited to:

• Additional contact information for notifications such as mobile numbers or addresses;
• IP address;
• Country of Residence;
• Field of study;
• Hobbies;
• Personal interests;
• University application stage;
• Worries, motivations, key decision drivers and aspirations related to your prospective or current university experience;
• Education level; 
• Profile pictures where added by End User; and
• Any other Personal Data requested by the Customer.

CampusThreads acting as a Processor

Where Customers provide Personal Data of their Ambassadors and End Users, CampusThreads acts as a Processor of such Personal Data. Such Personal Data may include but is not limited to:

• Contact information such as telephone numbers or addresses;
• IP address;
• Country of origin;
• Field of study;
• Personal interests;
• Education level;
• Any relevant Personal Data collected and provided by the Customer; or
• Any other Personal Data, including conversation data, voluntarily provided by End Users through the use of the Platform services including but not limited to the widget, and CampusThreads Events.

Information we receive from other sources

When using our Platform, we will be in contact with third parties who may provide us with certain information about you in order to enable your use of the Platform:

• Customers.  CampusThreads receives the Personal Data as set out below to enable Customer’s End Users to access the CampusThreads Platform.
• Service providers. For example, we may use analytics service providers to analyse how you interact and engage with the Platform, or third parties may help us provide you with customer support. We also use customer experience companies who conduct user interviews, for example, who may share your personal data with us when we want to find out more about your opinion and experience of using our services.  You will be notified by those third parties before they share your personal data with us.
• Social networks connected to the services. If you provide your social network account credentials to us via the bio field or otherwise sign in to the Platform through a third-party site or service, you understand some content and/or information in those accounts may be transmitted into your Account with us.
• Partners. If you sign up to access CampusThreads through a third party partner website, CampusThreads and/or our partner may indicate that certain data will be shared with that third party.

How we use your information and justification of use

• Use of personal information under certain data protection laws must be justified under one of a number of legal “grounds” and the Customer is required to set out the ground in respect of each use of your Personal Data in their Privacy Policy. These are the principal grounds that justify the use of your Personal Data:
• Consent: where you have consented to the use of your information (you are providing explicit, informed, freely given consent, in relation to any such use and may withdraw your consent in the circumstance detailed below by notifying Us or the Customer);
• Contract performance: where your information is necessary to enter into or perform a contract with you;
• Legal obligation: where we need to use your information to comply with legal obligations;
• Legitimate interests: where we use your information to achieve the University’s legitimate interest and the reasons for using it outweigh any prejudice to your data protection rights; and
• Legal claims: where your information is necessary to defend, prosecute or make a claim against you or a third party.

In respect of the use of the Platform, CampusThreads (whether acting as Controller, Joint Controller or Processor) uses information held about you (and information about others that you have provided us with) in the following ways:

Types of Information Collected by End User	Use Justification	Lawful Basis
All End Users
First name, surname, email, phone number	To provide you with access to our Platform and any other information which you request from us and to notify you of changes to our Platform	Contract performance, legitimate interest (to provide all users with updated information in the event the Platform change)
First name, surname, email, phone number	To enable you to communicate with Ambassadors using the Platform and other End Users via CampusThreads Community (if applicable).	Contract performance, legitimate interests (to provide access End Users and Ambassadors when the Customer had enabled the feature on the Platform)
First name, surname, email, phone number	To send automated product communications and re-engagement communications for inactive accounts as part of the Platform	Legitimate interest (to ensure the database is accurate and up to date and communicate with users)
Information we collect about you (as detailed above)	To administer and improve the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes in a pseudonymised manner. To conduct and facilitate user experience research, including to gauge feedback on new products and features in early stages of development, to determine whether those new products and features would be of sufficient value to users. To ensure the content on our Platform is presented in the most effective manner for you and your computer or mobile device	Contract performance, legitimate interest (to improve the Platform and report internally on usage and gain insight on user basis at a statistical level)
Conversation history and information submitted when interacting with End Users and Ambassadors (as applicable).Conversations can also be ‘tagged’ to group conversations under certain topics.	To allow End Users to interact as part of the Platform. To enable the Customer to analyse Ambassador conversations.Unless an exception applies, the conversation history will not identify the End User, but will identify the Ambassador.To provide a high level summary of the conversational data to the Customer.	Contract performance, legitimate interests (to allow the Customer to assess the type of questions being asked and the quality and appropriateness of the responses), (to the extent you provide any sensitive personal data in any free text box, you are consenting to the processing of such sensitive Personal Data)Legitimate interest (to understand the queries End Users are asking and compile more appropriate responses)
Ambassadors
Your first and last name;photo; phone number, email address, encrypted password; country/city/location, country flag; languages spoken; academic history (and previous high school; degree/university degree; degree level (undergraduate/postgraduate);current area of study;university year (1st, 2nd etc.);Occupation; andHobbies, interests and societies; and an ‘about me’ free text selection.	To provide a public bio of the  Ambassadors in order for End Users to find the appropriate person to interact with.	Contract performance, consent (to the extent you provide any sensitive personal data in any free text box, you are consenting to the processing of such sensitive personal data).
Customer Staff and Other Customer End User:
First and last name email address, encrypted password;Mobile phone number;Country;The degree level you are interested in, (undergraduate or postgraduate) and area of study; whether you have already applied to the university; andChat conversations and interactions with Ambassadors.Customers may request additional Personal Data to be processed for use of the Platform.	To enable End Users to   engage with Customers.	Contract performance, consent (to the extent you provide any sensitive personal data in any free text box, you are consenting to the processing of such sensitive Personal Data).Legitimate interest (to ensure the database is accurate and up to date and communicate with users).
First name, surname, email, the degree and level of study you are interested in and your country of origin.Customers may request additional Personal Data to be processed for use of the Platform.	To enable Customers to market products and services that they believe will be of interest to you.	Consent (you have the right to unsubscribe at any time by contacting the Customer).
CampusThreads Events – Ambassador and Customer staff email and names (presenter only)	To enable the Customer to make use of various webinars created by the Customer as CampusThreads Event Recordings	Consent (you have the right to request deletion of the Recording by contacting the Customer)

We will not sell or share your personal data (or any other data you provide us with) to third-parties; however, we reserve the right to share any data (including but not limited to conversational data and questions and answers),  which has been anonymised to improve the Platform and for analysis, research, product development, trend analysis and benchmarking. 

Where we store your personal information

Your Personal Data is maintained, processed and stored by us and our authorized Service Providers (defined below) in the USA. We may also retain your Personal Data in other locations as reasonably necessary for the proper performance and delivery of our Platform, or as may be required by law.

While privacy laws may vary between jurisdictions, CampusThreads and its affiliates and Service Providers are each committed to protect Personal Data in accordance with this Privacy Policy and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in their jurisdiction.

Customers based outside of the USA and Canada will be subject to local data privacy legislation. A full list of our third party Service providers/Sub-processors and details of their privacy policies can be found here, which will be updated from time to time. By using our Platform you consent and agree with the Sub-processors we use above. Where we have made changes and have provided you with an updated list of our Sub-processors, we will provide you with a notification and provide 30 days’ notice to determine whether you agree with the changes and continue to use our Platform or alternatively you can discontinue using our Platform.

You acknowledge and accept that countries outside of the USA and Canada may not provide the same level of adequate protection for the rights and freedoms of data subjects in relation to the processing of personal data.

Your passwords are stored on CampusThreads’ servers in encrypted form. We do not disclose your account details to anyone except when legally required to do so. It is your responsibility to keep your password secure. Unfortunately, the transmission of information via the Internet is not completely secure. Although CampusThreads will do its best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent any unauthorized access.

Disclosure of your information

We may also disclose your personal information to third parties in the following circumstances:

Purpose of disclosure and third party(s) to which disclosure might be made	Use Justification
CampusThreads may share certain Personal Data with Customers and Partners where the applicable third party acts as a Joint Data Controller or Processor. Such Personal Data may include: Personal Data submitted in the creation of a CampusThreads account (such as name, email, etc); any Personal Data submitted via the Platform, services such as the widget, provided that conversation data on the CampusThreads widget will not normally identify an individual unless justified under exceptional legal grounds.	Contract performance, legitimate interest (to allow our service providers to provide the necessary services).
We may disclose your Personal Data to our service providers (to assist us in performing any contract we enter into with them or you, including providing the Website and the services it enables), analytics providers, and/or a member of our group.	Contract performance, legitimate interest (to allow our service providers to provide the necessary services).
If CampusThreads or substantially all of its assets are acquired by a third party, personal information about our customers will be one of the transferred assets.	Legitimate interest (to sell our Company or assets), Consent (for sensitive personal data).
If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation or to protect the rights, property, or safety of CampusThreads, our Customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection. For End Users – in the event you are in a breach of our Acceptable Use Policy or where we are under a lawful obligation to share your Personal Data, we might share it with the university, including conversation history.	Legal obligation.
We may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.	Legal obligation (to cooperate with law enforcement and regulatory authorities).

How long we retain your personal data

We will hold the above information for as long as is necessary in order to provide you with the ability to use our Platform, deal with any specific issues that may arise, or otherwise as is required by law or any relevant regulatory body. For End Users for which CampusThreads acts as a Data Controller, you may delete your account at any time, following which your Personal Data will be immediately and securely deleted.

Some Personal Data may need to be retained for longer to ensure CampusThreads can comply with applicable laws and internal compliance procedures, including retaining your email address for marketing communication suppression if you have opted not to receive any further marketing. If information is used for two purposes, we will retain it until the purpose with the latest period expires but we will stop using it for the purpose with a shorter period when that period expires.

We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymized (and the anonymized information may be retained) or securely destroyed.

Your rights

• General Data Protection Regulation (The Personal Information Protection and Electronic Documents Act (PIPEDA), you have various rights in relation to your Personal Data.
• Ambassadors, Customer employees and Students should contact the Customer in the first instance as their Data Controller. 
• All other End Users should contact CampusThreads in the first instance as their Controller or Joint Controller at team@campusthreads.co.

The Data Controller, is primarily responsible for ensuring you can exercise these rights and the data Processor, shall assist the Data Controller to effectively exercise your rights.

• You have the following rights in relation to your Personal Data.

Rights	Details
Right to access	You have the right to access Personal Data held by the Controller(s), including a description of your data. Personal Data processed can be found in the profile section of your CampusThreads account, while further information is available on request.
Right to rectification/correction	You have the right to rectify any details to ensure that your personal information is accurate. In order to assist with this, you should notify the Data Controller of any changes to the personal information that you have provided by sending a request to rectify your personal data where you believe the Personal Data collected is inaccurate or incomplete.
Right to erasure/ ‘Right to be forgotten’	Asking the Controller(s) to delete all of your Personal Data will result in the deletion of your personal data held by that Controller without undue delay (unless there is a legitimate and legal reason why the Controller is unable to delete certain Personal Data, in which case you will be informed of this in writing).
Right to restriction of processing	You have the right to ask the Controller to stop processing your Personal Data at any time in certain circumstances. Such a request will result in the Controller restricting its processing of such data.
Right to complain	You have the right to lodge a complaint to a supervisory authority such as the Information Commissioner’s Office in Canada. Although we encourage our customers to engage with us in the event they have any concerns or complaints.

CampusThreads will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the Personal Data undergoing processing this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs.

Requests to stop processing your Personal Data or deleting your Personal Data will likely mean that you are no longer able to use CampusThreads’s Platform, or at least those aspects of the Platform which require the processing of the types of Personal Data you have asked us to delete, which may result in you no longer being able to use the Platform.

Where you exercise any of your rights above, the Controller may notify third parties to whom such Personal Data has been disclosed of such request. However, such third parties may have the right to retain and continue to process such personal data in its own right. 

Subject Access Request/Valid Request

To exercise the rights described above, you must send us a Subject Access Request/Valid Request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request.

“Authorized Agents”: you may submit a request to know or a request to delete your Personal Information through an Authorised Agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity and submit proof of residency with us. If you have submitted a request via Authorised Agents and have followed the prescriptions above, we shall count these requests as Valid Requests.

We will work to respond to your Valid Request within a 30 day period of receipt for all Valid requests under GDPR and 45 days of receipt under CPPA/CPRA. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request by: sending an email to team@campusthreads.co; or by post to: CampusThreads Network Corp, PO BOX 30057 TORONTO RPO DOVERCOURT, ON M6J 3V3.

Cookies

CampusThreads and our third-party partners, such as our analytics partners, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different Services and devices. For more information, please see our Cookie Policy, which includes information on how to control or opt out of these cookies and tracking technologies.

By visiting or logging into our website, cookies and related technologies may be employed by our data partners or vendors to connect your actions with personal information they or others may possess, including your email address. This information may be used by us or our service providers to deliver marketing messages or other communications to your email. If you prefer not to receive these advertisements, you can opt out by visiting our opt-out URL

Third party websites

Our Website may, from time to time, contain links to third party websites. If you follow a link to any of those third party websites, please note that they have their own Privacy Policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third party websites.

Changes to this policy

Any changes we make to our privacy policy in the future will be posted on this page. When we make significant changes, we will make such changes clear on this page, or by some other means of contact such as email or notifications via the CampusThreads Platform. Your continued use of the Platform and the Website shall be deemed your acceptance of the varied Privacy Policy.

Contact

If you have any questions and comments about this Privacy Policy or want to report a potential data breach please address these to team@campusthreads.co