PRIVACY POLICY

PLEASE READ THE FOLLOWING PRIVACY POLICY CAREFULLY.

This Privacy Policy describes the policies and procedures of CapSource Education, LLC, a Delaware limited liability company (“CapSource,” “we” or “us”) on the collection, use, and disclosure of your information when you use our Services, via the Site.

This Privacy Policy is incorporated into and is subject to our End-User License and Terms of Service (our “Terms of Service”). Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Service which can be found at www.capsource.io/terms.

If you do not agree to the terms of this Privacy Policy, then you may not use our Services. We reserve the right to modify this Privacy Policy or our Terms of Service at any time without prior notice to you. You agree that each visit you make to the Site will be subject to our then-current Privacy Policy posted on the Site and your continued use of our Services now or following modifications in this Privacy Policy confirms that you have read, accepted, and agreed to be bound by such modifications. The term “you” or “user” shall refer to any person or entity who uses, downloads, accesses, browses, or otherwise utilizes the Site or uses or receives any Services.

  1. Information Collection. We collect the following information (collectively, “Personal Information”):
    1. User-Provided Information: You may provide to CapSource what is generally called “personally identifiable” information (including your name, email address, postal mailing address, home/mobile telephone number, demographic information, date of birth, social security number, driver’s license state and number, financial information, credit card information, employment information, residency or credit proof information, and insurance information) when using our Services. We may collect and store this personally identifiable information.  If you correspond with us by email, we may retain the content of your email messages, your email address, and our responses.  If you use your Facebook, Twitter, or other social networking site (“SNS”) account information to sign in to our Services, we will collect and store your SNS user ID. If you connect your CapSource account with your SNS account (such as to enable posting from CapSource), we ask for your permission to collect certain information from your SNS account (such as information from your SNS profile).  You also provide us information in connection with your use of our Services, your communications, order history, and any other information shared from your use of our Services, and metadata about this use (such as time and location, if applicable) are collected and stored by us.
    2. “Cookies” Information: When you use our Services, we may send one or more cookies (small text files containing a string of alphanumeric characters) to your computer. These cookies (a) store your username and password, (b) analyze the usage of our Services, (c) customize our Services to your preferences, and (d) control the advertising displayed by our Services. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services. Persistent cookies can be removed. Please review your web browser “Help” file to learn the proper way to modify your cookie settings.  If you would like to prevent us from collecting cookies when you visit our site, please update the privacy setting in your chosen web browser. Please note that if you delete, or choose not to accept, cookies from our Services, you may not be able to utilize the features of our Services to their fullest potential.
    3. Location Information: We may collect different types of information about your location, including general information (e.g., Internet Protocol address and zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access our Services), and may use that information to customize our Services with location-based information and features. If you access our Services through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this.
    4. “Automatically Collected” Information: When you use our Services or open one of our HTML emails, we may automatically record certain information from your web browser by using different types of technology, including “clear gifs” or “web beacons.” This “automatically collected” information may include Internet Protocol address or other device address or ID, web browser, and/or device type, the web pages, or sites that you visit just before or just after our Services, the pages you view on our Services, and the dates and times that you visit our Services.
    5. Information from Other Sources: We may also obtain information, including personally identifiable information, from third parties and sources other than CapSource, such as advertisers or other users who import your email address from their address book. We may also, at your direction, receive information from third party service that provide a mechanism to expose information you have provided to such third party through the use of an application program interface (API), such as Facebook Connect. If we combine or associate information from other sources with personally identifiable information that we collect through our Services, we will treat the combined information as personally identifiable information in accordance with this Privacy Policy.
  2. Information Usage. We use your Personal Information to operate, maintain, enhance, and provide all of the features and services found on our Services. We may use your email address to send you Services-related notices (including any notices required by law, in lieu of communication by postal mail). You can control receipt of certain Services-related messages on your profile settings page and/or by emailing [email protected]. We may also use your contact information to send you marketing email messages. If you do not want to receive such messages, you may opt out by following the instructions in the message.  We use all of the Personal Information to understand and analyze the usage trends and preferences of our users, to improve the way our Services work and look, and to create new features and functionality. We may use “automatically collected” information and “cookies” information to: (a) personalize our Services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit our Services; (b) provide customized third party advertisements, content, and information; (c) monitor and analyze the effectiveness of our Services and third party marketing activities; (d) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (e) track your entries, submissions, and status in any promotions or other activities.
  3. Information Protection. We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Information. We cannot, however, ensure or warrant the security of any information you transmit to us or guarantee that your Personal Information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice through our Services if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach you should notify us at [email protected].
  4. Information Disclosure. Your privacy is very important to us. We do, however, disclose your Personal Information in a variety of circumstances at our discretion including, as follows:
    1. We may share or sell automatically collected and other aggregate non-personally-identifiable information with interested third parties to assist such parties in understanding the usage, viewing, and demographic patterns for certain programs, content, services, advertisements, promotions, and/or functionality on our Services.
    2. We work with third party service providers to provide website hosting and maintenance as well as other services for us. To the extent it is necessary for these service providers to complete their contractual obligations to us, these third parties may have access to or process your Personally Information. Generally, these disclosures are made under terms comparable to this policy, and the recipients are limited to using the information the purpose for which it was provided.
    3. We may also disclose your Personal Information if required to do so by Law or in the good-faith belief that such action is necessary to comply with Law, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement activity.
    4. We also reserve the right to disclose your Personal Information that we believe, in good faith, is appropriate or necessary to take precautions against liability; to protect us and others from fraudulent, abusive, or unlawful uses or activity; to investigate and defend ourselves against any third party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of our Services; or to protect the rights, property, or personal safety of CapSource, our users, or others.
    5. We share relevant information about Projects and Users with partner organizations and other Users in the normal course of business in order to provide and improve the Services. For example, (i) we share information about Student Users with Companies Users when a Company Users is considering posting a Project or to select a Student User for a Project and (ii) we share information about Company Users and Project listing with prospective Student Users, school, programs, or other potential Users or partner organizations.
  1. Your Choices. You may, of course, decline to share certain personally identifiable information with us, in which case we may not be able to provide to certain Services to you. You may update, correct, or delete your profile information and preferences at any time by accessing your account preferences page and/or by emailing [email protected]. Please note that while your changes are reflected promptly in active user databases, we may retain all information you submit for a variety of purposes, including backups and archiving, prevention of fraud and abuse, and analytics.To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your information. You are responsible for maintaining the secrecy of your unique password and account information at all times.
  2. Children’s Privacy. We do not solicit or knowingly collect personally identifiable information from children under the age of 13 without parental consent. If we learn that a child under the age of 13 has provided us with personal information, we will delete it in accordance with applicable law.
  3. Third Party Sites. Our Services contain links to websites and services provided by third parties.  Please remember that when you use a link to go from our Services to another website, our Privacy Policy is no longer in effect.  Any personally identifiable information you provide on third party sites or services is provided directly to that third party and is subject to that third party’s policies, if any, governing privacy and security. We are not responsible for the content or privacy and security practices and policies of third party sites or services to which links are displayed on our Services. We encourage you to learn about third parties’ privacy and security policies before providing them with personally identifiable information.
  4. International Visitors. This Site is hosted in the United States via Amazon Web Services. If you are an international visitor, you should note that by providing your Personal Information, you are: (a) permitting the transfer of your Personal Information to the United States which may not have the same data protection laws as the country in which you reside; and (b) permitting the use of your Personal Information in accordance with this Privacy Policy. Your Personal Information may be collected, transferred to and stored in countries outside the European Economic Area (“EEA”) as we use AWS and other similar remote, cloud-based website servers hosts to provide the website and some aspects of our Services, which may be based outside of the EEA, or use servers based outside of the EEA – this is generally the nature of data stored in “the Cloud.” It may also be processed by staff operating outside the EEA who work directly for us or one of our suppliers, e.g. our website server host. A transfer of your Personal Information may happen if any of our servers are located in a country outside of the EEA or one of our service providers is located in a country outside of the EEA.  If we transfer or store your personal data outside the EEA in this way, we will take steps with the goal of ensuring that your privacy rights continue to be protected, as outlined in this Privacy Policy and in accordance with the Data Protection Act 1998 (“DPA”) and the General Data Protection Regulations (“GDPR”).The DPA and GDPR give you the right to access Personal Information held about you by us. Please write to us or contact us by email if you wish to request confirmation of what Personal Information we hold relating to you. You can write to us at [email protected].  There is no charge for requesting that we provide you with details of the Personal Information that we hold. We will respond to your request for the data within a reasonable amount of time.You have the right to change the permissions that you have given us in relation to how we may use your Personal Information. You also have the right to request that we cease using your Personal Information or that we delete all Personal Information records that we hold relating to you. You can exercise these rights at any time by writing to us at the address detailed above, or by email to [email protected].
  5. Your California Privacy Rights. California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year. To obtain this information, please send an email to [email protected] with the phrase “California Privacy Request” in the subject line and in the body of your message.If you are a resident of California, under the age of 18 and have registered for an account with us, you may ask us to remove content or information that you have posted to our websites. Please note that your request does not ensure complete or comprehensive removal of the content or information, because, for example, some of your content may have been reposted by another visitor to our websites.  To make sure a request, please send an email to [email protected] with the phrase “California Privacy Request” in the subject line and in the body of your message.
  6. In the Event of Merger, Sale, or Bankruptcy. We reserve the right to transfer all Personal Information in our possession to a successor organization in the event of a merger, acquisition, or bankruptcy or other sale of all or a portion of our assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personal Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and an opportunity to affirmatively opt-out of it. Personal Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by our successor organization.
  7. Changes to Our Privacy Policy. Please revisit this page periodically to stay aware of any changes to this Privacy Policy, which may be revised periodically at our sole discretion.  If we change our privacy policies and procedures, we will post those changes on this page to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Your continued use of the Services following the posting of changes will mean that you accept the updated Privacy Policy.
  8. Our Contact Information. If you have any questions about our practices or this privacy policy, please contact us at [email protected].

 

Last Updated: November 8th, 2018