Privacy policy

Last updated: July 22, 2026

1. Introduction

This privacy policy (the “Policy”) sets forth the types of information that CFR Nominees USA, LLC, a Texas limited liability company d/b/a CAMPFRONT (“Provider”, “us”, “we”, “our” and their variants), may collect from or about Authorized Users or Attendees, and our practices for collecting, using, and disclosing that information. As used in this Policy, “you” (and its variants, “your” and “yours” etc.), means the person interacting with or using the Platform.

This Policy is part of the Terms applicable to the use of the Platform. Please review this Policy together with the Terms, to understand all of your rights and obligations, and how we operate the Platform. Any capitalized terms used but not defined in this Policy shall have the meanings ascribed to them in the Terms.

This Policy applies to information we collect or you provide:

Via the Platform;
Via any message or correspondence with Provider;
When you interact with our advertising and applications on third-party websites and services, if such advertising or applications include links to this Policy; and
Through any other means associated with or relating to the Platform.

This Policy does not apply to information collected by:

Us offline or through any other means, including on any other website operated by Provider or any third party (including our affiliates and subsidiaries); or
Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Platform.

Please read this Policy carefully to understand our policies and practices regarding personal information and how we will treat it. By using the Platform, each Camp and Authorized User expressly agrees to be bound by this Policy, and by its continued use, each Camp and Authorized User indicates its continued acceptance of the Policy. If Camp or an Authorized User does not agree to the Policy, it must not access or use the Platform.

This Policy may change from time to time. Camp’s and Authorized User’s continued use of the Platform after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

CAMP AND EACH AUTHORIZED USER HEREBY ACKNOWLEDGE THAT WE MAY USE SERVICE PROVIDERS AND THIRD-PARTY TECHNOLOGIES, INCLUDING COOKIES, PIXELS, WEB BEACONS, ANALYTICS SERVICES, AND OTHER TECHNOLOGIES THAT TRACK ACTIVITIES ON THE PLATFORM, AND COLLECT DATA ABOUT AUTHORIZED USERS AS YOU NAVIGATE THE PLATFORM. THESE THIRD PARTIES AND SERVICE PROVIDERS MAY INTERCEPT COMMUNICATIONS, COLLECT DATA ABOUT AUTHORIZED USERS, MONITOR INTERACTIONS WITH THE PLATFORM, TRACK AUTHORIZED USER ACTIVITIES ON THE PLATFORM AND ACROSS DIFFERENT CHANNELS, AND MAY COLLECT ENOUGH INFORMATION ABOUT AN AUTHORIZED USER AS THEY USE THE PLATFORM TO BE ABLE TO IDENTIFY THEM ON THEIR OWN PLATFORMS (E.G., SOCIAL MEDIAL PIXELS). BY USING THE PLATFORM, AUTHORIZED USERS SPECIFICALLY CONSENT TO THIS INTERCEPTION, TRACKING AND DATA COLLECTION.

2. Information we collect or you provide

We collect or you provide several types of information on the Platform, including of Camps, Authorized Users, and Attendees. The type of information we may collect regarding Camps, Authorized Users, and Attendees includes:

Personally identifiable information of Authorized Users or Attendees, such as name, birth date, address, email address, telephone number or any other identifier provided to us through the Platform or that we may require when a Camp or an Authorized User registers and creates an Account on the Platform (including, for Camp Participants, profile information and other information uploaded to the Platform as part of engaging, applying and seeking Camp Opportunities);
Information posted to the Platform which does not specifically identify an Authorized User or Attendee, but is related to them and may be considered sensitive or confidential, including, without limitation, healthcare-related or other medical information (e.g., notation that an Attendee has a specific medical condition that requires special meals or medications), and Parental Users’ payment information;
Information about the device used to access the Platform, including your device characteristics and functionality (including information about your operating system, hardware, mobile network, browser, browser language, etc.);
Your IP address, Identifier for Advertisers, Android/Google Advertising ID, International Mobile Equipment Identity, or another unique identifier;
Referring and exit web pages and URLs;
Your browsing history, including the areas within the Platform that you visit and your activities there, including remembering you and your preferences;
Your device location or other geolocation information;
Certain other device data, including the time of day you visit the Platform; and
Information about your internet connection and internet provider.

We and our service providers may collect this information:

Directly from Camps or Authorized Users (including when you create an Account, when Data is input into the Platform by an Administrator or other Authorized User, when an Authorized User requests something from us, when a Camp Participant creates a profile, submits an application, or completes onboarding activities, etc.);
Automatically as you navigate through the Platform, including through the use of automated data collection technologies (including information about your network or computing device) and analytics services;
From third parties, for example, our business partners and service providers;
Records and copies of your correspondence (including email addresses), if you contact us through the Platform;
When you engage in transactions on the Platform; and
When you contact our customer service agents, if available.

3. Automatic data collection technologies

Through your use of the Platform, certain information may be automatically collected via automatic data collection technologies. This information may include, without limitation:

Details of your visits to the Platform, other communication data, and the resources that you access and use on the Platform.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

You acknowledge and understand that our service providers will be collecting this information about you, and may monitor and intercept your communications and actions on the Platform as you browse, interact with or use certain functionality, such as chat features. These service providers may use the information they collect for their own benefit, without any restriction. You specifically agree to this arrangement, and consent to your communications and information being intercepted by our third party providers.

The information we collect automatically may be statistical data and may also include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. This information enables us to:

Allow you to use and access the Platform;
Prevent fraudulent activity and improve security functionality;
Assess the performance of the Platform, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Platform;
Offer you enhanced functionality when accessing the Platform, including identifying you when you sign into the Platform, and keeping track of your specified preferences; and
Estimate our audience size and usage patterns.

The technologies we use for automatic data collection may include:

Cookies or browser cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of the Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Platform;
Flash Cookies. Certain features of the Platform may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Platform. Flash cookies are not managed by the same browser settings as are used for browser cookies and you may not be able to shut down our collection of and use of information through this technology;
Web Beacons, Pixels and Tags. Pages of the Platform and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity);
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Platform, such as information about the links you click on;
ETag, or entity tag. An ETag, or entity tag, is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. It is one of several mechanisms that HTTP provides for web cache validation. These allow websites to be more efficient and not serve content again, when data is already cached and ready to view;
Fingerprinting. Fingerprinting refers to the collection and analysis of information from your device, such as your operating system, plug-ins, system fonts and other data, for purposes of identification;
Recognition Technologies. Recognition technologies refers to various technology features used by websites, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user); and
Log Files. These track actions occurring on the Platform, and which help us collect your IP address, browser type, Internet service provider, the webpages from which you came or to which you go before and after visiting the Platform, and the date and time of your visits.

4. Third-Party Products

Certain Third-Party Products are integrated within the Platform for use, which may include, but are not limited to, payment processing product(s) and certain SMS messaging products. The providers of such Third-Party Products may collect, access, use, store, or otherwise process your personal information in connection with your use of such Third-Party Products, subject to their applicable terms and privacy policies.

For the sake of clarity, Provider does not store, access, or process, the full credit card number, expiration date, or security code of any Camp or Authorized User.

5. Do Not Track

Do Not Track (“DNT”) is a concept promoted by certain regulatory authorities and industry groups for development and implementation of a mechanism that would allow internet users to control the tracking of their online activities across websites. Currently, various browsers (including Internet Explorer, Firefox, and Safari) offer a DNT option that allows a user to set a preference in the browser to not have his/her activities on the internet tracked. You can usually access your browser’s DNT option in your browser’s preferences. When a user’s browser is set to DNT, some cookies and other tracking technologies may become inactive, depending on how the website visited responds to DNT browser settings. If that occurs, the website or platform visited will not recognize you upon return, save your passwords or user names, and some other features of a website or platform may become unavailable or not function properly. Given the lack of a standard in the industry or any clear regulatory guidance on this issue, we do not comply with DNT signals from your browser at this time.

6. Third-party use of cookies and other tracking technologies

Some content or applications, including advertisements, on the Platform may be served by third-parties, such as our payment processors and SMS service providers. These Third-Party Product operators may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

7. How we use your information

We use personal information that we collect on or through the Platform (except as otherwise set forth herein or in accordance with applicable law):

To make our Platform available for use to Camps and Authorized Users;
To allow Camps and Authorized Users to create Accounts;
To provide Camps and Authorized Users with information, products, or services requested from us;
To allow you to participate in interactive features on the Platform;
To provide you with notices about your Account and your Camp/Attendees and, as applicable, Camp Opportunities, and/or the Platform;
To allow Camps to post and administer Camp Opportunities;
To allow Camp Participants to create and maintain profiles, search for Camp Opportunities, express interest in Camp Opportunities, and submit applications;
Improve the Platform, including by analyzing Data and creating aggregated, de-identified, anonymized data derived from information you input in the Platform (the “Aggregated Data”) to develop, maintain, analyze, improve, optimize, and measure the Platform and its features and how Camps and Authorized Users interact with the Platform;
To carry out our obligations and enforce our rights arising from any contracts entered into with Camps and Authorized Users, including for billing and collection, if needed;
To notify Camps and Authorized Users about changes to the Platform or any products or services we offer or provide though it;
To develop and improve our products and services;
For any other purpose as needed for our business;
In any other way we may describe when you provide the information; and
For any other purpose with your consent.

We do not use your information to contact you about third-parties’ goods and services that may be of interest to you. We do not disclose your personal information or other information to any third party for this purpose except as may be set forth below.

8. Updating personal information

Camps and Authorized Users must keep their Account information updated at all times, which can be done on the Platform.

9. Disclosure of your information

Parental Users recognize that all information input to the Platform about themselves and their Attendees will be shared with the Camp that the Attendees will be attending, and third party service providers who support our business (e.g., hosting companies, payment processors, etc.).

We may disclose personal information that we collect as described in this Policy, including:

To our affiliates;
To each Camp to which a Camp Participant applies, expresses interest in, or otherwise engages with;
To a parent or legal guardian of a Attendee;
To contractors, service providers, and other third parties we use to support our business and assist us in providing the Platform and our services;
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Provider’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information is among the assets transferred;
To fulfill the purpose for which the information is provided to us;
For any other purpose disclosed by us when you provide the information;
With your consent;
To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
To enforce or apply the Terms, including this Policy, and any other agreements between us, Camps, and Authorized Users, including for billing and collection purposes; and
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Provider, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

We may disclose information that does not identify any individual without restriction.

10. Aggregated Data

Notwithstanding anything herein to the contrary, each of Camp and Authorized User grants to Provider a license to use certain Data it inputs into the Platform to create the Aggregated Data. For the avoidance of doubt, the Aggregated Data is de-identified and anonymized and does not contain any identifiable information of any person. Provider may disclose Aggregated Data without restriction.

11. Data security

We have implemented measures intended to secure personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. However, the safety and security of your information also depends on you. You are responsible for keeping your Account login credentials confidential. You must never share your password with anyone and you are required to change your password from time to time. We also highly recommend that you use a password that is dissimilar to and cannot be easily found by unauthorized third parties who may have obtained your login credentials to other sites. Keep in mind that if you use the same password for all websites/platforms, if someone obtains your credentials for one site, they may be able to then use those credentials to log into any other site you use.

Unfortunately, the transmission of information via the internet is not completely secure. Although we try to protect your personal information, we cannot guarantee its security. Any transmission of personal information is at your own risk.

We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

12. California residents

California Civil Code Section § 1798.83, known as the “Shine The Light” law, permits users of the Platform who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding year, and the names and addresses of those third parties. You may request this information from us no more than once a year, but such request will be handled by us free of charge to you. To make such a request, please send an email to support@campfront.com.

13. State and international privacy rights

State consumer privacy laws and international data protection laws may provide certain residents with additional rights regarding our use of personal information. The exact scope of these rights may vary by state or international government. To exercise any of these rights please contact us at support@campfront.com.

14. Changes to our Policy

This Policy may be amended from time to time by Provider, and no prior notice of any such amendment(s) shall be required to be delivered to you. All changes to the Policy are effective when posted by Provider. Your continued use of the Platform following the posting of a revised Policy means that you accept and agree to the revised Policy. You are expected to check this page frequently so you are aware of any changes, as they are binding on you.

15. Contact information

To ask questions or comment about this Policy and our privacy practices, contact us at support@campfront.com.