Privacy Policy

Effective date: May 17, 2016

ChromaUp Privacy Policy

Effective date: May 17, 2016

The ChromaUp website and mobile applications (the “Services”) are operated by Chroma Education, Inc. ChromaUp is committed to respecting and protecting your privacy. To that end, we have prepared this privacy policy (“Privacy Policy”) to describe our information gathering and dissemination practices and our data protection practices for the Services. Please read this Privacy Policy carefully so that you understand our privacy practices. If you do not agree to this Privacy Policy, do not use the Services or give us any of your information. The terms “ChromaUp,” “we,” “us,” and “our” refer to Chroma Education, Inc. and its subsidiaries and affiliates. The terms “you,” “your,” and “yours” refer to the user/customer utilizing the Services. This Privacy Policy is governed by our Terms of Use.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices and the ways you can help protect your privacy.

Our Privacy Policy applies to all visitors, users, and others who access the Services (“users”).

SUMMARY

We adhere to the following principles to protect your privacy:

  1. We do not rent or sell your personal information to third parties without your consent, except as described in this Privacy Policy or as required by law.
  2. We do not share any information you have provided to us except as specified in this Privacy Policy, unless compelled by law, or as necessary to enforce our Terms of Use or protect the rights, property, or personal safety of ChromaUp, its users, and the public.
  3. All information that you provide will be protected with industry standard protocols and technology.

COLLECTION OF INFORMATION

INFORMATION YOU PROVIDE TO US

ChromaUp offers the Services, a platform used by its users, including students, alumni, participating colleges and universities, community organizations and participating companies. We collect information you provide directly to us. For example, we collect information when you create an account, create or edit your profile, create or edit portfolios, fill out a form, participate in a contest or promotion, request customer support, send us an email, or otherwise communicate with us. The types of information we may collect include your name, email address, username, password school information, and other contact or identifying information you choose to provide, as well as photographs, video, comments and other information you include in any timeline or other materials you create through the Services.

Participating schools, colleges & universities may register students, alumni, and participating companies before they become a ChromaUp member and provide us various information about such parties, including, but not limited to, their name, email address, location, and in the case of students or alumni, their degree program, and graduation year. If you are a student, when you sign up to become a member of ChromaUp, you can confirm such information and provide us other information about yourself such as your education history, intended major, career preferences, activities, passions, interests, and job history. Any information provided to us at registration may be used by ChromaUp as described in our Terms of Use and this Privacy Policy.

INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU USE THE SERVICES

When you access or use the Services, we automatically collect information about you, including:

  • Log Information: When you use our Services, our servers automatically record certain log file information, including, but not limited to, your web request, internet protocol (“IP”) address, internet service provider (“ISP”), browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Services, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Services.
  • Device Information: We collect information about the computer or mobile device you use to access the Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
  • Metadata: Metadata is usually technical data that is associated with user content. For example, Metadata can describe how, when and by whom a piece of user content was collected and how that content is formatted. You can add or may have Metadata added to your user content including a hashtag (e.g., to mark keywords when you post a photo), geotag (e.g., to mark your location to a photo), comments or other data. This makes your user content more searchable by others and more interactive. If you geotag your photo, video or other media or tag them using other’s APIs then, your latitude and longitude will be stored with the photo, video or other media and searchable if such media is made public by you in accordance with your privacy settings.
  • Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that helps us to improve and customize the Services and your experience, see which areas and features of the Services are popular and count visits. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in the Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. We use cookies for authentication and to maintain the user’s current session. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited. For more information about cookies, and how to disable them, please see “Your Choices” below.

We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the Services, and to gather demographic information about our user base as a whole. We do not link this automatically­collected data to personal information.

We and our partners, educational establishments, affiliates, or analytics service providers use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the website, track users’ movements around the Services, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

INFORMATION RELATED TO DATA COLLECTED THROUGH THE CHROMA SERVICES

As stated above, if you are a student, ChromaUp may collect some personal information about you under the direction of your college or university, prior to any direct relationship established with you through signing up for our Services. ChromaUp works with colleges and universities to help them provide notice to their students concerning the purpose for which personal information is collected.

Choice: If you are a student at a school, middle school, high school, secondary school, college, or university that works with ChromaUp, and prefer to decline having your personal information aggregated and shared, please contact us to request that your information not be shared. Your college’s or university’s privacy standards and practices concerning the sharing of your personal information with third parties are not governed by this privacy policy. Contact your school for information about their privacy policy regarding your personal information.

Sub­Processors: ChromaUp may transfer personal information to companies that help us provide our Services. For example, we use sub­processors in order to send emails on our behalf or on behalf of our customers. Transfers to third parties are covered by the provisions in this Privacy Policy regarding notice and choice and the service agreements with such third parties.

Access: ChromaUp may not have a direct relationship with the individuals whose personal data it processes. If you seek to correct, amend, or delete inaccurate data in connection with the Services, you may do so through the settings in your user profile. If you seek to correct, amend or delete data about you that has been provided to us by your school, middle school, high school, secondary school, college, or university, you should direct your request to your school, middle school, high school, secondary school, college, or university. If your school, middle school, high school, secondary school, college, or university requests ChromaUp to correct, amend or delete some or all of the data they have provided to us, we will respond to their request within a reasonable timeframe.

Data Retention: ChromaUp will retain personal information we process on behalf of participating schools, middle schools, high schools, secondary schools, colleges, universities, and companies for as long as needed to provide services to them. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

USE OF INFORMATION

We may use information about you for various purposes, including to:

  • Provide, maintain and improve our Services;
  • Provide and deliver the products and services you request, process transactions and send you related information, including confirmations and invoices;
  • Send you technical notices, updates, security alerts and support and administrative messages;
  • Respond to your comments, questions and requests and provide customer service;
  • Communicate with you about products, services, offers, promotions, rewards, and events offered by ChromaUp and others, and provide news and information we think will be of interest to you;
  • Monitor and analyze trends, usage and activities in connection with our Services;
  • Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests;
  • Process and deliver contest entries and rewards;
  • Link or combine with information we get from others to help understand your needs and provide you with better service; and
  • Carry out any other purpose for which the information was collected.

ChromaUp is based in the United States and the information we collect is governed by United States law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in the United States and to other countries.

SHARING OF INFORMATION

We may share information about you as follows or as otherwise described in this Privacy Policy:

  • With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
  • In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation, including, but not limited to, civil and criminal subpoenas, court orders, or other compulsory disclosures;
  • To enforce our user agreements or policies;
  • To respond to claims of a violation of the rights of third parties, whether or not the third party is a ChromaUp user, individual, or government agency;
  • To respond to customer service inquiries;
  • To protect the rights, property and safety of ChromaUp, our users, or others;
  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; and
  • Your portfolios or other information with (a) various schools, middle schools, high schools, secondary schools, colleges, universities, (b) community organizations and other entities that help students; provided that such entities and organizations will only be provided information on an aggregated or anonymized basis, or (c) companies so long as we notify you that the information you provide will be shared in a particular manner and you provide such information.

We may also share your personal information and other information you provide to another third party as a part of a sale of the assets of ChromaUp, or as the result of a change in control of the company. If ChromaUp is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

You understand that when you use the Services, your profile and other information you post and actions you take through the Services, including, but not limited to, your profile, your timeline, direct messages, posts on public forums, emails, nudges, push notifications, and chat services, may be shared with other users and may be viewable on publicly available areas of the Services, depending on the applicable privacy settings. For more information about how privacy settings work, please see “Your Choices” below.

PUBLIC INFORMATION

Our Services are designed, among other things, to help you share information with colleges & universities and put your best digital foot forward. When you share information or content like photos, videos, and information via the Services, you should think carefully about what you are making public.

ANALYTICS SERVICES

We may use third parties to provide analytics services. These entities may use cookies, web beacons and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by ChromaUp and others to, among other things, analyze and track data, determine the popularity of certain content, customize the Services, deliver content targeted to your interests on our Services and other websites and better understand your online activity.

For example, we may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Services and enhance your experience when you use the Services. For more information on how Google uses this data, go to http://www.google.com/policies/privacy/partners.

LOCATION INFORMATION

When you use the Services, the Services may request that you provide your city and state of residence. Please keep in mind that other users of the Services, participating colleges and universities, community organizations and participating companies, may be able to view your city and state of residence in connection with the Services, if it is made publicly available. We may also use your location information in an aggregated way, as described above.

SOCIAL NETWORKING INTEGRATIONS

One of the special features of the Services is that it allows you to enable or log in to the Services via various social networking services like Facebook or Instagram (“Social Networking Service(s)”). By directly integrating these services, we make your online experiences richer and more personalized. To take advantage of this feature, we will ask you to log into or grant us permission via the relevant Social Networking Service. When you add a Social Networking Services account to the Services or log into the Services using your Social Networking Services account, we will collect relevant information necessary to enable the Services to access that Social Networking Service and your data contained within that Social Networking Service. As part of such integration, the Social Networking Service will provide us with access to certain information that you have provided to the Social Networking Service, and we will use, store and disclose such information in accordance with this Privacy Policy. However, please remember that the manner in which Social Networking Services use, store and disclose your information is governed by the policies of such third parties, and ChromaUp shall have no liability or responsibility for the privacy practices or other actions of any Social Networking Services that may be enabled within the Services.

You may also have the option of posting your Services activities to Social Networking Services when you access content through the Services (for example, you may post to Facebook that you performed an activity on the Services). You acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services may be able to view such activity.

SECURITY

In order to help secure your personal information, access to your data on ChromaUp is password ­protected, and sensitive data is protected by reasonable security when it is exchanged between your web browser and the ChromaUp website. To protect any data you store on our servers, ChromaUp also regularly audits our system for possible vulnerabilities and attacks, and we use a tier­one secured­access data center. It is your responsibility to protect the security of your login information. Please note that emails, push notifications, instant messaging, and similar means of communication are generally not encrypted, and we strongly advise you not to communicate any confidential information through these means. We do share your information with participating colleges & universities so they may discover and engage with you, so be cognizant to show yourself in the best possible manner. We cannot control the actions of other users with whom you share your information. We cannot guarantee that only authorized persons will view your information. We are not responsible for third party circumvention of any privacy settings or security measures on ChromaUp. You can reduce these risks by using common sense security practices such as choosing a strong password, using different passwords for different services, and using up­to­date antivirus and malware software.

You should also report any security violation to us at hello@chromaup.com or by postal mail at Chroma Education, Inc., 3031 Tisch Way #408, San Jose, CA 95128.

You should also report any inappropriate content on ChromaUp to us by clicking “Report User” on ChromaUp’s platform.

CHILDREN’S PRIVACY

ChromaUp does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the Services. The Services and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at hello@chromaup.com.

DECEASED USER

In the event of the death of a ChromaUp user, please contact us at hello@chromaup.com. We will usually conduct our communication via email. Should we require any other information, we will contact you at the email address you have provided in your request.

LINKS TO OTHER WEBSITES

Our Services includes links to other websites and platforms whose privacy practices may differ from those of ChromaUp. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any websites or platforms you visit. Third parties may collect, but we do not authorize them to collect, personally identifiable information about your online activities over time and across different websites when you use our Services.

YOUR CHOICES

PRIVACY SETTINGS

You may elect to restrict access to certain information, such as who can view your profile, by contacting us at hello@chromaup.com or by accessing your privacy settings. It is important to note that regardless of the privacy settings you select for your own profile, information that you post and actions that you take on or in connection with other users’ profiles or in other areas of the Services may be viewable by other users and may be publicly available, depending on the applicable privacy settings for that application feature, e.g., messaging which could use a third party application.

ACCOUNT INFORMATION

You may update, correct or delete information about you at any time by logging into your online account, or emailing us at hello@chromaup.com. If you wish to delete your account, please email us at hello@chromaup.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a reasonable period of time.

COOKIES

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

PROMOTIONAL COMMUNICATIONS

You may opt out of receiving promotional emails from ChromaUp by following the instructions in those emails or by emailing ChromaUp at hello@chromaup.com. If you opt out, we may still send you non­promotional communications, such as those about your account or our ongoing business relations.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at hello@chromaup.com or by postal mail at Chroma Education, Inc., 3031 Tisch Way #408, San Jose, CA 95128.