Welcome to the ManageCamp Inc. Websites and Apps
(www.ManageCamp.com, www.BrandManageCamp.com) (collectively, the “Website”) operated by or on behalf of ManageCamp Inc., a Colorado company located at 7950 S. Lincoln St., Suite B-106, Littleton, CO 80122 (“ManageCamp”, “MC”, “we”, “our”, or “us”). This Privacy Policy is intended to inform you about how your personal data (PD) is collected by us in operating the Website.
This policy is prepared in compliance with the requirements of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), as in force from time to time. Where a particular provision applies to EU-based users only, we have made this clear. Our nominated person for data protection issues is Katy Herstein and her contact details are contactus@managecamp.com.
The Website is accessible via a computer, laptop, mobile tablet, or mobile phone, and via the Brand ManageCamp App associated with each Brand ManageCamp Event. “App” means any third-party application downloadable through Google Play or Apple’s App Store or any other venue or facility(including any updates/upgrades to that app). When the word “Website” is used herein it expressly includes each and every Brand ManageCamp App.
The Brand ManageCamp App facilitates the transmission of a list of installed apps on your device to a third party’s server, namely, one or more of the following systems and entities managing those systems: Document Management System, Email System, Disaster Recovery Repositories, Contact Management System, Registration System, Invoicing System, Electronically Stored Information Platforms, Phone System, or Calendaring systems. These systems are also used directly by ManageCamp. This information may be used to provide you with advertisements, promotions or information that are better suited to your interests or updates regarding the Brand ManageCamp Events for which you have registered. If you do not agree to the transmission of a list of your installed Apps to a third party, please do not install the App. If you do not agree to ManageCamp’s use of these third-party systems, please update your ManageCamp Account Preferences accordingly.
To assist you in reading our Privacy Policy, we have provided answers to the following frequently asked questions:
o Who is the Data Controller?
o How does the Website work?
o What type of PD does MC collect from you and how do we use it?
o Why MC collects your PD
o Under what circumstances may we share your PD?
o What are your rights in respect of your PD?
o Opting Out
o What other information does MC collect?
o How do we store information?
o Do we transfer information to other nations?
o Does MC provide links to other websites?
o What are our policies regarding children?
o California Privacy Rights
o For how long does MC keep PD?
o Do we have a mechanism to address complaints about the handling of information that we collect?
Who is the Data Controller?
The Data Controller is ManagCamp Inc., who will ensure that the PD is processed pursuant to applicable laws, including, without limitation (i) the General Data Protection Regulation (EU) 2016/679 (GDPR) and any laws which implement, replace, extend, re-enact, consolidate or amend the GDPR, and (ii) the Federal Data Protection Act of 19 June 1992 (Switzerland).
How does the Website work?
The Website offers visitors to the Website (“you” or “your”) the opportunity to browse the Website and use certain features on the Website. By using the Website, you consent to the collection and use of your PD by MC as described herein. MC reserves the right to change how we handle the PD we collect through the Website at any time. We will update this Privacy Policy to reflect any changes in our privacy collection and handling practices, and will indicate that changes to this Privacy Policy have been made by listing a new date under “Last Updated” at the end of this Privacy Policy. Such changes will take effect immediately once posted to the Website.
What type of PD does MC collect from you and how do we use it?
MC does not require you to provide us with any PD. Unless you provide your PD to MC through the Website, we will not collect any PD from you. However, in order to use certain functionality (including, for example, to subscribe to our newsletters) on the Website, to register for and attend our Events, to receive Event updates as to dates, times and places, to participate in promotions offered from time to time or to purchase products through the Website, you will need to provide certain PD to us. PD may include your name, your personal address, the identity of your employer, your business address, your email addresses, your gender, your age, your location, your phone number, and/or your financial information (credit or debit card).
Why MC collects your PD
MC collects your PD for the purposes described in the above section titled “What type of PD does MC collect from you and how do we use it?” The lawful basis for which we process your information is:
o your consent
o processing is necessary for the performance of a contract to which you are a party. If you fail to provide this information, we may be unable to perform the contract.
o processing is necessary for compliance with our legal obligations.
o processing is necessary for the purpose of a legitimate interest pursued by us or a third party, except where your rights as a data subject override our legitimate interest.
Under what circumstances may we share your PD?
By clicking “I consent” upon registration, or by downloading the App, or by using certain Website functionality, you have agreed that MC may share your PD with other entities who work on our behalf or with us, such as one or more of the following systems and entities managing those systems: Document Management System, Email System, Disaster Recovery Repositories, Contact Management System, Registration System, Invoicing System, Electronically Stored Information Platforms, Phone System, or Calendaring systems. These entities may use your PD to help fulfill your requests in connection with the Website, to help us communicate with you about different resources offered as part of the Website or for other purposes. Also, our parent, subsidiary and affiliate companies, or entities to which any of our assets, products, sites or operations may be transferred, will be able to use your PD.
By clicking “I consent” upon registration, or by downloading the App, or by using certain Website functionality, you have agreed that on occasion, MC may share your PD with third parties for special features and marketing purposes.
If you are based in the EU, we will only use your PD for electronic marketing purposes if we are allowed to do this by law or if we have your consent. If you agree to us providing you with marketing information, you can always opt out at a later date. If you would rather not receive marketing material from us, please let us know at any time by contacting us using the details in the “Opting Out” section of this Privacy Policy, below.
What are your rights in respect of your PD?
You have the right to access, correct or delete PD about you as well as the opportunity to object to the processing of the PD by MC, which you may exercise at any time by submitting a written request to us at:
ManageCamp Inc., 7950 S. Lincoln St., Suite B-106, Littleton, CO 80122, Attn: Legal or by sending an optout request using the following link at contactus@managecamp.com .
If you are based in the EU, the following rights apply to you:
If you have created an account with us, you can sign into your account to access and update your information. You can manage your marketing preferences at any time by logging into your online ManageCamp user account and updating your preferences or by uninstalling the App.
You have the right to ask us to confirm whether we are processing information about you, and to request access to this information (“right of access”). You also have the right to be informed of the safeguards we have in place relating to any transfers of your information to another country.
You may ask us, or we may ask you, to rectify information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate or complete information which is incomplete (“right to rectification”). If you inform us that your PD is inaccurate, we will inform relevant third parties with whom we have shared your PD so they may update their own records.
We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided us with changes, for example if you change your email address, name, payment details, or if you wish to cancel your registration, please let us know using the contact details in the “Contact Us” section at the end of this Privacy Policy.
You have a right to obtain your PD from us and reuse it for your own purposes, perhaps for another service, without hindering the usability of the PD (“right of portability”).
You have a right to seek the erasure of your personal data (often referred to as the “right to be forgotten’”. You may wish to exercise this right for any reason – for example where it is no longer necessary for us to continue holding or processing your personal data – and you may withdraw your consent. You should note that we are entitled to and reserve the right to retain your data for statistical purposes. This right is not absolute, as we may need to continue processing this information, for example, to comply with our legal obligations.
You have a right to ask us to restrict our processing of your information (“right to restriction”) if:
o you contest its accuracy and we need to verify whether it is accurate
o the processing is unlawful and you ask us to restrict use of it instead of erasing it
o we no longer need the information for the purpose of processing, but you need it to establish or defend legal claims
o you have objected to processing of your information being necessary for the purposes of our legitimate interests. The restriction would apply while we carry out a balancing act between your rights and our legitimate interests.
o you exercise your right to restrict processing, we would still need to process your information for the purpose of exercising or defending legal claims, protecting the rights of another person or for public interest reasons.
You have a right to prevent us from processing your data for the purposes of marketing.
If you would like to exercise any of your rights above, please let us know using the contact details in the “Contact Us” section at the end of this Privacy Policy. We will act in accordance with your instructions as soon as reasonably possible and there will be no charge.
You have a right to report any of your concerns about our use of your data to the relevant data protection authority in your EU country.
Opting Out
You may opt-out of features or from receiving certain communications from us by logging into your online ManageCamp user account and updating your Account Preferences. If you would rather us not share your PD with any third party or other marketing purposes, please either (1) do not submit PD to MC through the Website or (2) indicate your desire for us not to share your PD with third parties for marketing purposes by submitting such a request in writing (an “Opt-Out Request”) to us at:
ManageCamp Inc., 7950 S. Lincoln St., Suite B-106, Littleton, CO 80122, Attn: Legal or by sending an optout request using the following link at contactus@managecamp.com .
If you opt-out of receiving communications related to the ManageCamp Events for which you have registered, then you may not receive notifications of changes of dates, times and venues. In such an event you agree that MC shall not be responsible or liable, directly or indirectly, for damages or loss caused or alleged to be caused in connection with your lack of knowledge about such notifications. You acknowledge and agree that if you opt-out, you will not receive any refunds or any other compensation.
Please note that it may take time for us to comply with your Opt-Out Request and, in the interim, we may continue to use your PD as described in this Privacy Policy. In addition, please note that after receiving your Opt-Out Request, we may continue to maintain your name and other PD in our records to help us ensure we can honor such requests to communicate to you about your account, and for other purposes not related to direct marketing. If we receive your Opt-Out Request after having shared your PD with a third party, MC may not be able to control use of such PD by such third party (or any other party to whom such third party may have transferred your PD), but MC will inform the third party of your request to opt-out. In such an event you agree that MC shall not be responsible or liable, directly or indirectly, for damages or loss caused or alleged to be caused in connection with the use of such PD by any such third party or resulting from any such transfer or disposition. If you are concerned about MC sharing your PD with third parties or otherwise transferring or disposing of your PD, you should not provide your PD to MC. We may also release your PD to third parties if we believe such release is necessary (i) to comply with the law (e.g., a legal process or a statutory authorization), (ii) to apply or enforce our user or other agreements, (iii) to protect our rights or property, (iv) as part of a corporate reorganization, consolidation, merger, or sale of substantially all of the assets of MC, or (v) if we reasonably believe that a danger to any person requires disclosure of such PD.
What other information does MC collect?
We also may collect anonymous and aggregate information from you about your preferences in navigating the Website by using cookies, action tags and other methods. Cookies are small text files that identify your computer. We may use cookies to, among other things, monitor Website usage, customize Website features, identify your computer’s operating system and browser, and complete transactions. An action tag is a small, graphic image on a webpage that is designed to allow the website owner or a third party to monitor who is visiting a website by collecting the IP address of the computer to which the tag is sent, the URL of the webpage that the tag comes from and the time that such webpage was viewed. Tags may be associated with cookie information. We may also use such non-PD for promotional or other business purposes. If you do not want us to track such information about you, you can set your browser to warn you before accepting cookies and refuse cookies when your browser alerts you to their presence. You can also adjust the settings in your browser to refuse all cookies.
How do we store information?
We take commercially reasonable efforts to protect PD provided to us, and work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input. However, we cannot guarantee that such information will not be lost, disclosed or accessed by accidental circumstances or by the unauthorized or unlawful acts of others. We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law. If any breaches occur, MC will use its best commercial efforts to notify you of the breach in a timely fashion and in accordance with applicable law.
Do we transfer information to other nations?
We may transfer PD we have collected about you to someone other than you in a foreign country only if such transfer is conducted in accordance with the principles of the nation in which the PD was collected and of the nation to which the PD may be transferred.
If you are based in the EU, we will need to transfer your PD to the USA for the purposes listed in this Privacy Policy. We may also need to transfer your PD to other countries outside the EEA. In respect of any such transfer, rest assured that we will always ensure that it is subject to appropriate security measures to safeguard your PD.
Does MC provide links to other websites?
We may provide links to other websites or resources of possible interest to you. Because we have no control over unaffiliated websites to which we provide links, the collection and use of your PD and other information by such websites shall be subject to the policies and procedures of such websites and not this Privacy Policy, and we will have no obligation or liability therefor.
What are our policies regarding children?
You must be eighteen (18) years of age or older in order to use the Website. MC does not knowingly collect PD from anyone under eighteen (18) years of age. If you are based in the European Union, the above provisions relating to children’s privacy generally apply to children under the age of 16, but this may vary across different member states.
California Privacy Rights
California Civil Code Section 1798.83 allows users who are California residents to request information about the disclosure of their personal information to third parties for direct marketing purposes. To make such a request, please contact us by contactus@managecamp.com and using the heading “CALIFORNIA PRIVACY DISCLOSURE REQUEST”.
For How Long Does MC Keep PD?
We will only retain your PD for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for PD, we consider the amount, nature, and sensitivity of the PD, the potential risk of harm from unauthorized use, accessing or disclosure of your PD, the purposes for which we process your PD and whether we can achieve those purposes through other means, and the applicable legal requirements. For details of retention periods for different aspects of you PD, please contact us at contactus@managecamp.com . Contact us If you have questions or concerns about any of our information collection or handling practices, please contact us by e-mail at contactus@managecamp.com or write to us at ManageCamp Inc., 7950 S. Lincoln St., Suite B-106, Littleton, CO 80122, Attention: Privacy Policy.
Acceptance
You accept that your use of the Website conclusively establishes your acceptance of this Privacy Policy and the Terms of Service.
Last Update: June, 2020