Campfront Privacy Policy

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”, or “we”), may collect from you (the “User” or “you”) or that you may provide when you visit or access the software platform (the "Platform") and our practices for collecting, using, and disclosing that information. This Policy applies only to information we collect or you provide via your use of the Platform or via any message or correspondence between you and Provider.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. By using the Platform, User expressly agrees to be bound by this Policy, and by its continued use, User indicates its continued acceptance of the privacy policy. If you do not want agree to the Policy, you must not access or use the Platform.

2. Information We Collect or You Provide. We collect or you provide several types of information from and about Users of the Platform and Attendees (as set forth below). Some Users of the Platform access and use the Platform in connection with their dependent(s) who are attending (or intend to attend, “Attendee”), one or more summer or other camps operated by a third-party person or entity (a “Camp”). The type of information we may collect regarding our Users and Attendees includes:

1. Personally identifiable information of a User or Attendee, such as name, birth date, address, email address, telephone number or any other identifier by which a User may provide to us voluntarily through the Platform or by which we may require for you to register as a user of the Platform (collectively, the "Personal Information"); and/or
2. Information which does not specifically identify a User or Attendee, such as any information you may post to the Platform but which may be considered sensitive or confidential, including, without limitation, healthcare-related or other medical information.

For the avoidance of doubt, neither the Provider nor the Platform collects information directly from any Attendee. Attendees are not permitted to be Users of the Platform. Any such Personal Information or other information which is provided to the Provider or input into the Platform shall only be provided or input into the Platform by a User. Each User shall be over eighteen (18) years of age and the identity and age of such User shall have been verified prior to User’s grant of access to the Platform.

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

(i) Details of your visits to the Platform other communication data and the resources that you access and use on the Platform.

(ii) Information about your computer and internet connection, including your IP address, operating system, and browser type.

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.

4. Third Party Products. Certain third-party products are integrated within the Platform for use by User (each a “Third-Party Product”), which may include, but not be limited to, payment processing product(s) provided by Stripe, Inc. and certain SMS messaging products. For the sake of clarity, Provider does not store, access, or process, the full credit card number, expiration date, or security code of any User or any SMS messages sent or received by any User (unless such SMS messages are sent by Provider).

5. How We Use Your Information. We use information that we collect about you or which you provide about you (or an Attendee) us, including any Personal Information (except as otherwise set forth herein or in accordance with applicable law):

(i) To register you as a User.

(ii) To provide you with information, products, or services that you request from us.

3. To allow you to participate in interactive features on the Platform.
4. Improve the Platform, including by analyzing your information 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 Users interact with the Platform.
5. In any other way we may describe when you provide the information.
6. 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.

6. Disclosure of Your Information. The information that you provide to the Provider via the Platform is being provided for the purpose of being disclosed to and used by the applicable Camp for which the User is either an employee or is a User on behalf of an Attendee (a “Permitted Disclosure”). Other than a Permitted Disclosure, which Permitted Disclosure Provider is not directly making but is facilitating on User’s behalf, Provider does not disclose Personal Information (or any other information) that it collects or you provide as described in this Policy except, in compliance with applicable law, Provider may disclose information that we collect or you provide as follows:

(i) 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.

(ii) For any other purpose disclosed by us when you provide the information.

(iii) With your consent.

(iv) To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

7. Aggregated Data. Notwithstanding anything herein to the contrary, 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. In compliance with applicable law, Provider may disclose Aggregated Data to its parent, subsidiary, and affiliated companies in connection with improving the Platform and the legitimate internal business purposes of the Provider, its parent, subsidiary, and affiliated companies.

8. 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 hello@campfront.com.

9. 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 the 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.

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