PRIVACY POLICY

 

Vista Host, Inc. (“Parents and Alumni University Clubs”, University Clubs,”  “we”, and “us”) respects the privacy of visitors to the websites operated by us, including www.vistahost.com  and all subdomains and all social media accounts held or operated by or for us (collectively, the “Site”), and our mobile application (the “Application”) and related parent and alumni club member services (collectively, “Services”) made available or provided to you.  University Club has developed the privacy policies outlined below (this “Privacy Policy”) to demonstrate its commitment to protecting your privacy. This Privacy Policy describes the types of information that we collect, how that information may be used, with whom it may be shared, and your choices about such uses and disclosures. We encourage you to read this Privacy Policy carefully when using our Services. This Privacy Policy is intended to comply with privacy laws applicable to us and the operation of the Site and the provision of the Application and the Services.  This Privacy Policy, however, does not cover our offline privacy practices.

By accessing our Site or using the Application or the Services, you acknowledge your agreement to accept the practices described in this Privacy Policy and you consent to our processing of your information as set forth in this Privacy Policy now and as amended by us. “Processing” means using cookies or local storage on a computer/hand held device or using or touching information in any way, including, but not limited to: collecting, storing, deleting, using, combining and disclosing information.  Your continued use of the Site, the Application or the Services after the effective date of any modification to the Privacy Policy will be deemed to be your agreement to the changed terms.  You agree to review the Privacy Policy each time you use the Site or the Application so that you are aware of such modifications.

WHAT TYPES OF INFORMATION DO WE OBTAIN FROM THE APPLICATION OR THE SITES?

USER PROVIDED INFORMATION

User Provided Information is collected online when users voluntarily submit non-public personal information by downloading the Application, establishing an account, requesting information, sending or receiving electronic notices or other similar communications on the Site or via the Application.

The Application obtains the information you provide when you download and register the Application. Registration with us is optional. However, please keep in mind that you may not be able to use the main features offered by the Application or the Site unless you register with us.

When you register with us and use the Application or the Site, you generally provide: (a) your name, spouses name, student name, address, email address, age, graduation year, college major, username, password and other registration information; (b) information that you provide us when you contact us for help; and (c) information that you enter into our system when using the Application or the Site, such as contact information, club name etc.  This information is used to perform the Services.

AUTOMATICALLY COLLECTED INFORMATION

Automatically Collected Information includes both personally identifiable information and non-personally identifiable (or anonymous) information about you, such as pages most frequently accessed by you.  

The Application may collect certain personally identifiable information automatically, including, but not limited to: the type of mobile device that you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the Application.  Your IP address and/or user name may be collected automatically when you access the Site or the Services for purposes of processing your login to your account or enhancing your Site browsing via cookies or standard settings.

Anonymous information is used in a collective manner, and no single person can be identified by that compiled information (for example, the number of people who logged into the Site in a particular day).  Anonymous Information does not personally identify a specific user. This information is generally used for Site or Application analytics in order to improve the performance of our systems and the Services.

Certain portions of the Site may allow for you to post or submit personally identifiable information (such as a comment box on a particular page or a social media account) in a public forum on the Site.  Participation in these public forums requires the public release and dissemination of such information, and thus we cannot commit to treating such personally identifiable information confidentially in the same manner that other personal information will be treated under this Privacy Policy.  Participation in these features of the Site is voluntary; we are not responsible and shall not be held liable for any personally identifiable information posted by you in any of our public forums.

HOW IS LONG IS SUCH INFORMATION RETAINED AND HOW DO WE SECURE SUCH INFORMATION?

We will establish minimum and maximum retention periods based upon the type of information collected (i.e. sensitivity), the intended purposes and as otherwise may be legally required. We will retain User Provided Information for as long as you use the Application and until you request to delete your data. We will still keep your data on server after you uninstall the Application. If you would prefer for us to delete User Provided Information, please contact us at UniversityClubPrivacy@vistahost.com and we will respond in a reasonable time. Please note that some or all of the User Provided Information may be required in order for the Application to function properly.

We maintain commercially reasonable safeguards to ensure the security, integrity and privacy of the personally identifiable information provided by you. Such security safeguards are intended to be appropriate to the sensitivity the information collected.  To the extent that we transfer any personally identifiable information to third parties, we will use commercially reasonable efforts to assure that such third parties to whom we may transfer any such information have knowledge of our Privacy Policy and provide sufficient protection of such information.

We are committed to properly securing the personally identifiable information collected online.  To help us accomplish this, we take the following steps:

  • We employ internal access controls to ensure that the only people who see your information are those with a need to do so to perform their official duties.
  • We train relevant personnel on our privacy and security measures and applicable legal requirements.
  • We physically secure the areas where we hold hard copies (if any) of the information that we collect online.
  • We regularly back up the information that we collect online to insure against loss.
  • We use technical controls to secure the information that we collect online as appropriate, including but not limited to: encryption, firewalls, and password protections.
  • We periodically test our security procedures to ensure personnel and technical compliance.

Please be aware that, although we endeavor to provide reasonable security for information that we process and maintain, no security system can prevent all potential security breaches.

In addition, please note that User Provided Information and Automatically Collected Information stored on the Site will be collected, stored and processed in the United States of America.  This Privacy Policy, is intended to abide by the safe harbor principles published by the United States Department of Commerce regarding the collection, use and retention of data from the European Union and the Personal Information Protection and Electronic Documents Act (PIPEDA) regarding the collection, use, and retention of data from Canada.  For more information on the safe harbor framework, please visit the U.S. Department of Commerce’s website at http://export.gov/safeharbor/.

No transmission of data over the Internet is guaranteed to be completely secure.  It may be possible for third parties not under our control to intercept or access transmissions or private communications unlawfully.  If you choose to visit the Site or use the Application or Services, your visit and any dispute over privacy is subject to this Privacy Policy, including but not limited to limitations of damages and application of the law of the State of Texas and the laws, regulations, ordinances and treaties of the United States of America.

DOES THE APPLICATION COLLECT PRECISE REAL TIME LOCATION INFORMATION OF YOUR MOBILE DEVICE?

This Application does not collect precise information about the location of your mobile device. We collect your address information when you enter yourself while registering to the app or when you edit your profile from the Application.

DO WE USE COOKIES TO COLLECT INFORMATION OBTAINED BY THE APPLICATION OR THE SITE?

The Application and the Site may utilize a standard technology called a “cookie” to collect information about how the Application or Site is used.  A “cookie” is a small text file placed on your hard drive or mobile device storage by our web page server.  

Your browser is probably set to accept cookies.  However, if you would prefer not to receive cookies, you can alter the configuration of your browser to refuse cookies.  If you choose to have your browser refuse cookies, it is possible that some features of our Site, the Application or the Services will not function properly when you view them.

We do not combine anonymous information collected through cookies with other User Provided Information to determine who you are or your e-mail or IP address.  The Site can access the anonymous information only from a cookie sent by the Site.  We cannot access other cookies sent by other websites or the information contained in those other websites.  Additionally, we cannot learn your email or IP address through the use of a cookie.  

We use cookies to track usage of the Site, the Application and the Services and further customize your experience when you are visiting the Site or using the Application or the Services.  By tracking usage, we can best determine what features of the Site, the Application and the Services best serve the users.  Without cookies, the features would “forget” items that may be stored. The session information is deleted when your browser is closed.

The gathering of key information may be accomplished by the use of cookies.  In particular, we may collect an IP Address from all visitors to the Site or users of the Application. An IP Address is a number that is automatically assigned to your computer when you use the Internet.  We use IP addresses to help diagnose problems with our server, administer our Site, analyze trends, track users’ movement on the Site, gather broad demographic information for aggregate use in order for us to improve the Site, and deliver customized, personalized content.

On those pages of the Site or the Application not requiring your account login, you may decline to accept cookies by selecting an option on your browser to reject cookies.  However, some portions of the Site or the Application may require account login or account registration in order to access those features. In such case, we ask that you provide us with basic information on your account set-up page. Cookies enable our server to know that you are a registered user; therefore, our registration system requires that you accept the cookies from the Site.  Other websites linked to the Site also may send cookies; however we do not control such activities.

In certain instances on the Site or the Application, you may be asked to opt-in to the use of cookies before you will be given access.  You will only be asked to opt-in upon your initial visit to those portions of the Site only.  However, if you elect to not opt-in to the use of cookies, you may not be able to access those portions of the Site or the Application or your ability to use those features will be impacted.

HOW DO WE USE INFORMATION OBTAINED BY THE APPLICATION OR THE SITE?

Your privacy is important to us.  We will use the User Provided Information provided by you in accordance with good commercial practice and applicable law.  If you provide us with your e-mail address (or have done so in the past), we will send notifications, newsletters or e-mail offers to you in accordance with the account preferences opted by you.  When you set up your account (and at any time thereafter), you will select and control how User Provided Information is shared from your account settings. The default setting will select all types of email notifications offered by us.  Your email will be used for notifications or newsletters only.  We do not share your public email address with others in its public forums.

We also may use User Provided Information, for example, to provide notifications about certain features of our Site or the Application or the Services to measure consumer interest in our various services, and to inform you about various products and services offered (including both our own services and the services of others).  These offers may be based on information provided by you in your account settings, in surveys, from information that may indicate your preferences, as well as information available from external sources. These offers will come exclusively from us or our affiliates.  All offers are carefully developed to ensure that they meet our standards.  Our goal is to target offers to users who we believe will find them of value. The lists used to send you product and service offers are developed and managed under conditions designed to safeguard the security and privacy of your User Provided Information. By providing information using the Site, the Application or the Services, you warrant to us that your User Provided Information is reliable for its intended uses, accurate, complete and correct, and that you will promptly notify use if such information is no longer current or correct.

We also may use your User Provided Information collected via the Site or the Application in the performance of all Services in order to provide, maintain and improve our Services as well as to develop new products and services to be offered as part of the Services.  For example, we use information to analyze data, to improve our product algorithms and databases and to tune our outputs based on a particular individual’s patterns of usage of our Services.

DO THIRD PARTIES SEE AND/OR HAVE ACCESS TO INFORMATION OBTAINED BY THE APPLICATION?

As a general policy, we do not share, sell or trade User Provided Information with third parties without permission from the user.  However, we may provide your information to third parties directly involved in the operation, performance, support, hosting and/or maintenance of the Site, the Application or the Services and each product or service offered on the Site, including without limitation, our mobile application and website designers, hosts, service providers, technical consultants, and business partners and to advertisers and third party advertising networks and analytics companies as described below in this Privacy Policy. Any User Provided Information, however, will be used by such organizations only to perform their functions and/or to provide services in support of the Site, the Application or the Services, and as otherwise permitted by law or approved by you in accordance with this Privacy Policy.  Anonymous Information may at times be shared with our business partners and other third parties.

We also may disclose User Provided Information and Automatically Collected Information as required by law, such as to comply with any valid legal process, such as a subpoena, search warrant, statute or court order or similar legal process, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, or if we reasonably believe that you have committed unlawful acts or acts that may endanger the health or safety of another user or of the general public.  

We reserve the right to assign or transfer your information to any successor in interest to our business associated with the Site, the Application or the Services by merger, reorganization, sale of all or substantially all of our assets or equity interests or operation of law.  You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of such information, as well as any choices you may have regarding such information.

AUTOMATIC DATA COLLECTION AND ADVERTISING

We may work with analytics companies to help us understand how the Application is being used, such as the frequency and duration of usage. We may work with advertisers and third party advertising networks, who need to know how you interact with advertising provided in the Application, which helps us keep the cost of the Application low. Advertisers and advertising networks use some of the information collected by the Application, including, but not limited to, the unique identification ID of your mobile device and your mobile telephone number. To protect the anonymity of this information, we use an encryption technology to help ensure that these third parties cannot identify you personally. These third parties also may obtain anonymous information about other applications that you have downloaded to your mobile device, the websites you visit using your mobile device, your non-precise location information (e.g., your zip code), and other non- precise location information in order to help analyze and serve anonymous targeted advertising on the Application and the Site. We also share encrypted versions of User Provided Information in order to enable our partners to append other available information about you for analysis or advertising-related uses.  If you’d like to opt-out from third party use of this type of information to help serve targeted advertising, please visit the section entitled “Opt-out” below.

We provide our account users with an easy means to decline receiving notifications, newsletters or offers by email.  We recognize the importance of providing you with the choice to “opt-out.”  You can control the number of notifications sent by email by logging into your account and changing your account preferences.  If you prefer, you also can “opt-out” of receiving any email notifications by contacting our Privacy Officer at the Contact Address below.  All e-mail offers sent by us will inform you as to how you can “opt-out” or decline receiving further e-mail offers.  

In addition, you can opt-out of all information collection by uninstalling the Application.  You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You also can request to opt-out via email, at UniversityClubPrivacy@vistahost.com.

CAN I MAKE CORRECTIONS TO USER PROVIDED INFORMATION COLLECTED ONLINE?

Additionally, you may request to view the User Provided Information collected about you through your use of the Site or the Application operated by or for us by accessing your account on the Site.  If you prefer, you can send an e-mail to our Privacy Officer at the Contact Address below.  If you send your request by email, we will likely send such User Provided Information (or a summary thereof) to your email address on file for the account name in our database, or we will send such information to you in another secure manner.  If at any time you wish to change, correct or update your User Provided Information, or have it removed from our database, you may do so by accessing your user account on the Site.  You also may submit a change request to our Privacy Officer by sending an email to the Contact Address below.

DO WE COLLECT PERSONALLY IDENTIFIABLE INFORMATION FROM CHILDREN?

We do not knowingly solicit data from children or knowingly market to children. We are concerned about the safety of children and their use of the Internet.  Therefore, in accordance with the U.S. Children’s Online Privacy Protection Act of 1998, we do not knowingly request or solicit personally identifiable information from anyone under the age of 13 without prior verifiable parental consent.  In the event that we receive actual knowledge that we have collected such information without the requisite and verifiable parental consent, we will delete that information from our database as quickly as is reasonably practical. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at UniversityClubPrivacy@vistahost.com. We will delete such information from our files within a reasonable time.

WHAT ABOUT PRIVACY ON INTERNET WEBSITES LINKED TO THE SITE OR FOUND ON THE APPLICATION?  

You should be aware that other Internet websites to which you hyperlink from the Site or the Application may contain privacy statements that differ from our Privacy Policy.  We encourage you to read and understand such privacy policies and terms of use of any linked websites accessed by you.  If you decide to access such linked websites and/or provide any personal information to such linked websites, you do so entirely at your own risk. We are not responsible for such provisions, and expressly disclaim any and all liability related to such provisions.

HOW CAN CHANGES BE MADE TO THIS PRIVACY POLICY?

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here and informing you via email or push notification. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes. You can check the history of this policy by clicking here. If you do not consent to such changes you can delete your account by writing email at UniversityClubPrivacy@vistahost.com.

 

WHO CAN I CONTACT IF I HAVE QUESTIONS ABOUT THIS PRIVACY POLICY OR ANY CHALLENGES AS TO COMPLIANCE?

We have designated our Privacy Officer who can be contacted at the following address (“Contact Address”):

By Mail: Privacy Officer

Vista Host, Inc.

10370 Richmond Avenue Ste. 150

Houston, Texas 77042

By Telephone: (713) 267-5800

By Fax: (713) 267-5820

By Email: UniversityClubPrivacy@vistahost.com

Our Privacy Officer is accountable for our compliance with this Privacy Policy and applicable federal and state privacy laws. If you have any challenge concerning our compliance with this Privacy Policy, or if you have any questions about our purposes for the collection and retention of your User Provided Information or Automatically Collected Information, then please contact our Privacy Officer at the Contact Address and provide a description of your concerns sufficient in detail to permit the Privacy Officer to investigate your concerns and contact you.  It is our intent to make available to you through the Privacy Officer specific information about this Privacy Policy and our management of such information as may be required by applicable law.

We use a self-assessment approach to ensure compliance with this Privacy Policy and periodically verify that this Privacy Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with applicable laws, including without limitation the safe harbor principles.  We encourage you to raise any concerns using the contact information provided above.  

 

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