Last Updated: January 12, 2022
In the United States, and other jurisdictions where applicable, before collecting any personal information (“Personal Information”) from prospective students accessing HelloCampus for services, a “School Subscriber”—typically college, university or other school —is expected to notify their prospective students about appropriate information practices, as permitted by applicable law.
For purposes of GDPR, the School Subscriber is the Controller and HelloCampus is the Processor of a student’s Personal Information. The Controller determines the legal basis, means and purposes for processing the data, and HelloCampus, where applicable, follows the directions of the Controller who sends us the data.
When prospective students (or other end users) are set up for, invited to, or use HelloCampus for services, by the very nature of the usage and the service, data is collected. We gather prospective students’ Personal Information from the Student directly as they interact with our HelloCampus platforms, directly from prospective students’ devices, and directly from someone who invites users to communicate with them via HelloCampus (such as a campus tour guide). Some of this collection happens when a prospective student or someone who wants to communicate with them via HelloCampus (e.g., a campus tour guide or other prospective student) affirmatively submits that information. Some of our collection happens in the background – that is, it’s automatically collected when users interact with HelloCampus (an example of the data collected this way is the information about the student’s device or connection, or the information about feature usage.).
HelloCampus and/or our third-party service providers also automatically collect some information using methods such as cookies and confirmation of message delivery time stamps. Information automatically collected may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), operating system, and date/time of message deliver stamp. We use this information to provide and support the HelloCampus services. We do not use this information to deliver advertising or for any other purpose not related to the delivery and support of the services.
We may collect Personal Information about prospective students directly or from the School Subscriber and authorized users of the School Subscriber account, including Personal Information contained in “educational records,” as defined by FERPA. HelloCampus maintains this information on behalf and at the direction of the School Subscriber and does not use the information for other purposes except as permitted by FERPA and our applicable agreements with School Subscribers.
We use Personal Information collected from and about prospective students only as needed to deliver the functionality of the HelloCampus platforms, operate our business, and for use by School Subscribers at their direction as follows:
We may use all of the types of Personal Information that we collect for the following purposes, to the extent permitted by our agreements with our School Subscriber customers:
Some of the prospective students’ Personal Information is shared with other meeting participants, during the use of our HelloCampus Live service. For example, questions, comments, interests and other personal content shared by a prospective student in a live, online campus tour setting, including Personal Information, will be available to all other participants in that meeting. If the School Subscriber or a student shares an online campus tour link with another user who is not already in the tour, when that user tries to join the meeting, he or she will be able to see the list of other users in the meeting, as well as other invitees joining the meeting.
In order to optimize provision of the Service, we may collect broad geographic location (city-level location) information about where users are located when using HelloCampus. We use this information for service-related purposes (such as optimizing connections to our data center), supporting compliance, and customizing user experience with our service (e.g., language preference).
We may also use third-party service providers to help us provide the service, and they may have limited access to Personal Information in the process. We prohibit our service providers from selling Personal Information they receive from us or on our behalf and require them to only use that Personal Information in order to perform the services we have asked of them, unless otherwise required by law.
Personal Information we collect, we collect on behalf of our School Subscribers. (To use the technical term, we are the “Processor” of that Personal Information, acting as a service provider on behalf and at the direction of our School Subscriber, and our School Subscriber is the “Controller” or decision maker.) For example, the School Subscriber may determine which messages to record and store, how long the messages should be retained, and the like.
We are typically required to follow a School Subscriber’s instructions related to Personal Information we have collected on their behalf. On a School Subscriber’s instructions, we may provide reports to the School Subscriber containing Personal Information relating to the school’s account and prospective students’ use of surveys created by the School Subscriber.
This includes responding to a legally binding demand for information, such as a warrant issued by a law enforcement entity of competent jurisdiction, or as reasonably necessary to preserve HelloCampus’ legal rights.
HelloCampus does not share Personal Information with third parties other than the service providers described above, or as required by law, except at the direction and on behalf of a School Subscriber.
Maintaining the confidentiality, security, and integrity of prospective students’ Personal Information is a top priority. We use industry-standard security technologies, procedures, and organizational measures designed to help protect Personal Information from unauthorized access, use, or disclosure.
If a student or his or her parent would like to request to access, review, refuse further collection of, or delete the student’s Personal Information, please contact your school with your request. Because HelloCampus is required to comply with contractual confidentiality obligations related to our customers’ data, we are not able to respond to parental or student requests directly. School Subscribers may direct requests to access, delete or restrict further collection or use of a student’s Personal information to email@example.com
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