PRIVACY POLICY

Before we collect or use any personal information of an individual under the age of 13, Company is required to obtain permission from such user’s parent or legal guardian. Please contact us at 609-5485401 or [msklar@esfcamps.com with any questions you have about personal information we may have collected about your child. You may request that we delete this information or specify that we collect no more of your child’s information however such request may limit your child’s ability to continue using certain Company services. Company is required to verify the identity of anyone requesting information about a child under the age of 13 to ensure that the person is in fact the child’s parent or legal guardian.

Other than with respect to our third party technology service provider Company’s online virtual camp products do not require third party access to a child’s personal information. Users may be required to agree to our technology service provider’s terms and conditions, and privacy policy, the terms of which shall govern such third party’s use of you and your child’s personal information. The ESF Sites do not collect or retain any personal information from children except as needed to provide Company services.

Certain aspects of Company services provided on the ESF sites may involve audio and visual recordings and the ability for users to share their computer screen with Company and other users. To the extent you use such services, including but not limited to ESF online camp services, subject to our Privacy Policy, you acknowledge that (i) you may share your screen, and the contents thereof, with the Company and its employees and agents as well as other users of the ESF Sites; (ii) when participating in video conferences you and any other individuals or objects appearing in your camera will be viewed by Company and other users of the ESF Sites. Subject to the Terms of Use, Company may record and maintain copies of video conferences, including but not limited to camps and related activities, and utilize such recordings at its sole discretion for quality assurance purposes, marketing and Company’s internal business purposes.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).  We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes name, title, date of birth and gender.
• Contact Data includes mailing/billing address, email address and telephone numbers.
• Financial Data includes bank account and/or payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have used or purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you (or by your parent or guardian on your behalf), your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our ESF Sites, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data which is anonymized, de-identified or otherwise aggregated, such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We use different methods to collect data from and about you including: (i) directly from you when you provide it to us; (ii) automatically as you navigate through the ESF Sites; and (iii) from third parties, for example our business partners; each as described below. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us 

The information we collect on or through our ESF Sites may include:

• Information that you provide by filling in forms on our ESF Sites. This includes information provided at the time of registering to use our ESF Sites, subscribing to our service, posting material, participating in virtual camps, or requesting further services. We may also ask you for information when you report a problem with our ESF Sites.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys, questionnaires, interactive activities and other services that you participate in via the ESF Sites.
• Details of transactions you carry out through our ESF Sites and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our ESF Sites.
• Your search queries on the ESF Sites.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the ESF Sites, or transmitted to other users of the ESF Sites or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the ESF Sites with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies 

As you navigate through and interact with our ESF Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: (i) details of your visits to our ESF Sites, including traffic data, location data, logs, and other communication data and the resources that you access and use on the ESF Sites; and (ii) information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our ESF Sites and to deliver a better and more personalized service, including by enabling us to: (i) estimate our audience size and usage patterns; (ii) store information about your preferences, allowing us to customize our ESF Sites according to your individual interests; (iii) speed up your searches; and (iv) recognize you when you return to our ESF Sites.

The technologies we use for this 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 our ESF Sites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our ESF Sites.
• Flash Cookies. Certain features of our ESF Sites may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our ESF Sites. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons. Pages of our the ESF Sites 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 the Company, 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).

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. Disabling cookies may impact how you view and interact with the Sites, including rendering some features unusable. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s Sites. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Information About You We May Receive from Third Parties

We may receive personal data about you from various third parties and public sources including:

• analytics providers such as Google;
• platform service providers such as advertising networks Instructure;
• Contact, financial and transaction data from providers of technical, payment and delivery services such as Stripe and Square.

We, and our authorized third service providers, may use information that we collect about you or that you provide to us, including any personal information:

• To present our ESF Sites and its contents to you.
• To provide you with information, products, or services that you request from us.
• To notify you about changes to our ESF Sites or any products or services we offer or provide though it or other products or services which may be of interest to you
• To analyze trends and conduct research about improving our products, services and ESF Sites.
• To correlate information with other commercially available information to identify demographics and preferences to assist us in marketing efforts.
• To contact users for research, informational or marketing purposes.
• To learn about our users’ needs.
• To address information security and/or privacy practices control, network functioning, engineering, and troubleshooting issues.
• To investigate claims and/or legal actions, violations of law or agreements, and compliance with relevant applicable laws and legal process.
• To comply with law, or based on our good-faith belief that it is necessary to conform or comply with the law, or otherwise to disclose information to prevent fraud and reduce credit risks, to cooperate with police and other governmental authorities, or to protect the rights, property or safety of visitors to the ESF Sites or the public.
• To process or engage in a sale of all or part of our business, or if we go through a reorganization or merger.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account/subscription, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you or your parent or guardian and us, including for processing credit cards, billing and collection.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about our own goods and services that may be of interest to you and to display advertisements to you when you visit other websites via our third party ad placement vendors. If you do not want to receive marketing communications from us you can opt out by notifying us of your intent to unsubscribe from such communications either by clicking the “unsubscribe” link contained therein or contacting us at: sgambescia@esfcamps.com

We collect and process your personal information under the following lawful bases:

• With your consent as provided hereunder;
• Performance of a contract with you;
• As necessary to comply with a legal obligation; and
• To fulfill our legitimate interest in conducting our business, where your interests and fundamental rights do not override those interests including, but not limited to:
  • providing the services for which you have enrolled;
  • to keep our records updated;
  • to study how customers, use our products/services, to develop them and grow our business and inform our marketing strategy;
  • for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercises;
  • contacting you about our products, or responding to your requests.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• 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 Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our ESF Sites users is among the assets transferred.
• To fulfill the purpose for which you provide it. (e.g. payment processing)
• 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
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others
• To enforce or apply our terms of use available at https://esfcamps.instructure.com/login/canvas.

PLEASE NOTE TO THE EXTENT YOU ARE UTILIZING THE ESF SITES BY YOUR PARENT OR GUARDIAN WE MAY DISCLOSE CERTAIN INFORMATION ABOUT YOUR PARTICIPATION TO YOUR PARENT OR GUARDIAN.

You can ask us or third parties to stop sending you marketing messages at any time by (i) by following the opt-out links on any marketing message sent to you; or (ii) by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service experience or other transactions.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Under certain circumstances, you may have rights under data protection laws in relation to your personal data, which may include rights to the following:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at policy@esfcamps.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our ESF Sites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the ESF Sites like message boards. The information you share in public areas may be viewed by any user of the ESF Sites.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we can neither guarantee the security of your personal information transmitted to our ESF Sites nor can we guarantee that such information will not become publicly available. 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 ESF Sites. 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 up-to-date antivirus software on your electronic devices.

If you are visiting the ESF Sites from a location outside of the United States, your connection will be through and to servers located in the United States. All information you receive from the ESF Sites may be created on servers located in the United States, and all information you provide may be maintained on web servers and systems located within the United States. The data protection laws in the United States and other countries might not be the same as those in your country. By using the ESF Sites or submitting information to us, you specifically consent to the transfer of your information to the United States and to the facilities and servers we use, and to those with whom we may share your information.

California Civil Code Section § 1798.83 permits users of our ESF Sites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to policy@esfcamps.com or write us at the address listed below.

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

ESF, Inc.
750 E. Haverford Road, Bryn Mawr, PA 19010
Attn:     ESF Camps
policy@esfcamps.com
610-922-7100

Depending on where you reside you may have the right to make a complaint to your local supervisory authority for data protection issues.  We would, however, appreciate the chance to deal with your concerns first so please contact us.