Privacy Policy | ReachU LLC

ReachU LLC

Introduction

Thank you for choosing to be a part of the community at ReachU LLC (“the Company”, “we”, “us”, or “our”). We are committed to protecting your personal information, your right to privacy, and your right to control your personal data. If you have any questions or concerns about our policy, our practices, or any question regarding your personal information, please contact info@reachuapp.com.

When you use our mobile application and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. We hope you take the time to read through it carefully – it is important. If there are any terms in this policy that you do not agree with, please discontinue use of our mobile application and our services.

This privacy policy applies to all information collected through our mobile application (“the App”) and/or any related services, sales, marketing, or events (“Services”).

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

What Information Do We Collect?

In Short: We collect personal information that you provide us with such as email address, college of study, class, ethnicity, and other simple demographic fields. We also collect information that you generate by using the app like event attendance, page views, and assessment scores. We collect personal information that you voluntarily provide to use when registering to the App or when you generate data by using the App and its features. The personal information we collect includes email address, college of study, class, ethnicity, first-generation student, on-campus/off living. We do not collect phone numbers, location data, or literal names.

The information that you generate while using the App includes browsing history within the app, event attendance through check-in features, badge/goal setting achievements, and assessment scores. All information generated and held by the App is protected according to the Health Information Portability and Accountability Act of 1996 (HIPAA).

We also have internal procedures in places to safeguard your data including but not limited to: - Employee training on data privacy - Periodic risk assessments - Access log reviews We collect information regarding your mobile device such as model and vendor as well as the IP address through which you have accessed the App. We also collect information about push notifications sent by the App. We may request access or permission to certain features from your mobile device like your camera. You may change this access through your device settings. ReachU will never request access for location data. We may request to send you push notifications regarding your account or the App. If you wish to opt-out from receiving these types of communications, you may disable them in your device’s settings.

You may also request to opt-out of analytics processing of your data through the App.

How Do We Use Your Information?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you or your university, compliance with our legal obligations, and/or your consent.

We use personal information collected through your use of the App for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you or your university, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:
- To publish content in the App. Much of the information that you consume in the app is generated by your university. This information is safeguarded in the same manner as your personal data.

- To facilitate account creation and logon process. The information you volunteer during the signup process is used for demographic analysis and communication purposes.

- Request Feedback. We may use your information to request feedback and to contact you about your use of our App.

- To enforce our terms, conditions, and policies for business purposes, legal reasons, or contractual obligations. - To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

- To manage user accounts. We may use your information for the purposes of managing your account and keeping it in working order.

- To deliver services to the users. We may use your information to provide you with the requested service. - For other business purposes.

We may use your information for other business purposes such as data analysis, usage trends, determining effectiveness of university resources, and to evaluate and improve the App and your experience. We may use this information in aggregated and anonymized forms to dissociate it from individual users by excluding personal information. We may aggregate your data with other users to share performance metrics with your university. We will not use identifiable personal information without your consent.

Will Your Information Be Shared With Anyone?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill contractual obligations. We may process or share data based on the following legal basis:
- Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.

- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, government requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:
• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: data analysis, email delivery, hosting services or customer service. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.

• Business Transfers. We may share or transfer your information 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.

• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company, subsidiaries, joint venture partners or other companies that we control or that are under common control with us. This also includes the university that has subscribed to our app.

• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions. How Long Do We Keep Your Information? In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us to keep your personal information past the termination of the user’s account. When we have no ongoing legitimate business need to process your personal information, we will further anonymize it, if that is not possible we will store your personal information and isolate it from further processing until deletion is possible.

How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. Our service provider has completed several security evaluation processes that can be found at https://aws.amazon.com/compliance/?nc=sn&loc=3. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we do our best to protect your personal information, transmission of personal information to and from our App is at your own risk. You should only access the App within a secure environment.

We employ several organizational security measures including regular security risk assessments, access logging for sensitive information, and termination policies for employees who misappropriate your data. For more information about our specific security policies, please contact info@reachuapp.com.

What Are Your Privacy Rights?

In Short: You may review, change, or terminate your account at any time.

When you delete your account, we delete all your personal information and any/all information that you have generated while using the App. You may also request a log of the information you have generated, or request to make an amendment to your information.

Personal Data Opt-Out You may request to opt-out of data analysis and aggregation directly through the App.

Account Termination You may delete your account and all associated data at any time. Upon your request to terminate your account, we will deactivate your account and all associated information from our active databases. However, some information may be retained in our files to troubleshoot problems, assist with and investigations, enforce our Terms of Use and/or comply with legal requirements. Personal information will not be retained after account termination.

Controls For Do-Not-Track Features Most web browsers and some mobile operating systems and mobile applications include a DoNot-Track (DNT) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future we will inform you about that practice in a revised version of this privacy policy.

Do California Residents Have Specific Privacy Rights?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below or by using the above mentioned functionality in the App.
If you are under 18 years of age, reside in California, and have a register account with the App, you have the right to request removal of unwanted data that you publicly post to the App. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the App, but please be aware that the data may not be completely or comprehensively removed from our systems. Do We Update This Policy? In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we ay notify you either by email or a notice within the App. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information. How Can You Contact Us About This Policy? If you have questions or comments about this policy, you may contact our Data Protection Team by email at info@reachuapp.com.

Thank you for reading our privacy policy, enjoy ReachU!