C’reerTM Privacy Policy

Last updated: January 6, 2017

Thank you for using C’reer.  We are committed to protecting your privacy and, for that reason, we have adopted this Privacy Policy to explain our data collection, use, and disclosure practices for the C’reer services (including its website, and mobile and web-based applications, and any tools, products, or services provided by Vireo Labs Labs that link to or reference this Privacy Policy) (collectively, the “Services”).  The Services are owned and operated by Vireo Labs, LLC, a Delaware limited liability company (“Vireo,” “we,” “us,” or “our”). 

This Privacy Policy applies to information Vireo Labs collects through the Services, as well as other information provided to us online or offline by third parties, when we associate that information with customers or users of the Services; however, it does not apply to information collected from our employees, contractors, or vendors.  It also does not apply to information that you share with third parties or is collected by third parties through the Services (including colleges and universities).  You acknowledge and agree that we are not responsible for the data collection or use practices of any other Service user or third party utilized in providing the Services. 

This Privacy Policy describes, among other things: 

·       Personal and other information we collect about you;

·       How we use your information;

·       How we may share your information with third parties; and

·       Your choices regarding the personal information we collect about you.

1.     Consent

By accessing or using the Services, you consent to this Privacy Policy.  If you do not agree with this Privacy Policy, please do not access or use the Services.  Information gathered through the Services may be transferred, used, and stored in the United States or in other countries where our service providers or we are located.  If you use the Services, you agree to the transfer, use, and storage of your Personal Information (as defined below) in those countries. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. You agree that all transactions relating to the Services or C’reer are deemed to occur in the United States, where our servers are located.

2.     Collection of Your Personal and Other Information

When you register for, or use our Services, we collect Personal Information.  By “Personal Information” we mean information that can identify an individual, such as:

·       Names;

·       Personal or business addresses;

·       Email addresses;

·       Phone numbers; and

·       Information contained in any image, photograph or profile you submit to us.

We also collect information you provide when using the chat feature of our Services, which allows you to interact with Participating Schools (as further described in Section 4 below).  The information you provide in a chat may include Personal Information or non-Personal Information. 

Certain aspects of the Services may also access certain features of your mobile device, including its camera and location services (GPS), and collect information from those features, such as photographs for creating a profile picture, or your precise location for identifying schools in your region.  You consent to this access.

You may choose not to provide Personal Information or prevent the Services from accessing certain features of your mobile device (subject to the controls offered by your mobile device’s operating system), but this may prevent you from receiving certain features of the Services.

We also collect non-Personal Information relating to the Services, that is, information that does not personally identify an individual.  The non-Personal Information we collect includes how you interact with the Services, information generally collected or “logged” by Internet websites or Internet services when accessed or used by users, and information about your web browser or device accessing or using the Services. 

Examples of the non-Personal Information we collect are:

·       Demographic information, such as high school graduation year;

·       Your Internet Protocol (IP address);

·       Information about your computer or mobile device, such as its maker or operating system version, and HTTP header information;

·       The pages of our website that you viewed during a visit or the features of the C’reer mobile app you use;

·       What information, content, schools or advertisements you view or interact with using the Services;

·       Language preferences;

·       Location information, either from a zip code you provide us or from your phone’s GPS system; and

·       Unique identifiers, meaning arbitrary codes or series of characters we create or are provided from a third party to identify unique users or devices without Personal Information. 

We will not use non-Personal Information to try to identify you, and if we associate any non-Personal Information with information that personally identifies you, then we will treat it as Personal Information. As discussed in more detail below, we sometimes use cookies and other automatic information gathering technologies to gather non-Personal Information.

Information collected by the Services may be collected by us or one of our service providers, but in either case, this Privacy Policy will govern the collection, use, and sharing of the information.

3.     Use of Your Information

We may use the information we collect to:

·       Assist us in providing, maintaining, and protecting the Services;

·       Set up, maintain, and protect accounts to use the Services;

·       Improve our online operations;

·       Provide customer service;

·       Communicate with you, such as provide you with account- or transaction—related communications, or other newsletters, RSS feeds, and/or other communications relating to the Services;

·       Send or display offers and other content that is customized to your interests or preferences;

·       Perform research and analysis aimed at improving our products and services and developing new products or services; and

·       Manage and maintain the systems that provide the Services.

4.     Disclosure of Your Information

We may disclose your Personal Information to third parties as described below.   

The Services include information about colleges and universities.  We have a business relationship with some of these colleges and universities (“Participating Schools”).  We may disclose your Personal Information to Participating Schools when you view their information within the Services or we otherwise determine that the products or services offered by these schools is relevant to you.  You may provide additional information, including Personal Information, to Participating Schools through the chat or similar features of the Services. This Privacy Policy does not apply to a Participating School’s use of the information it receives through the Services.

We may disclose Personal Information to provide the Services, or when you authorize or instruct us to do so, for example when you use the Services to submit content or profile information. We may also disclose Personal Information and non-Personal Information to companies, agents, contractors, service providers, or others engaged to perform functions on our behalf (such as processing of payments, provision of data storage, hosting of our website, marketing of our products and services, conducting audits, and performing web analytics).  

We may partner with advertisers to provide you with special offers, or to advertise products or services to you.  If you redeem or respond to an offer, we may provide your Personal Information to the advertising partner, including your name, email address, and gender. If you answer questions or fill out surveys from an advertiser, we may share information with that advertiser as described in Section 2, above.  The advertising partner’s privacy policy will govern their use of your information, which may include marketing of other products or services to you.  You should read each advertiser’s privacy policy before providing information to that advertiser.

We may also disclose your Personal Information to third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary to (a) enforce or apply the terms and conditions of the Services, including investigation of potential violations thereof, (b) comply with legal or regulatory requirements or an enforceable governmental request, (c) protect the rights, property or safety of us, our users or other third parties, (d) prevent a crime or protect national security, or (e) detect, prevent or otherwise address fraud, security or technical issues.  Finally, we reserve the right to transfer information (including your Personal Information) to a third party in the event of a sale, merger, or transfer of all or substantially all of the assets of our company relating to the Services, or in the unlikely event of a bankruptcy, liquidation, or receivership of our business. We will use commercially reasonable efforts to notify you of such transfer, for example via email or by posting notice on our website.

Lastly, we may also disclose non-Personal Information, aggregated with information about our other users, to our clients, business partners, merchants, advertisers, investors, potential buyers and other third parties if we deem such disclosure, in our sole discretion, has sound business reasons or justifications. 

5.     Cookies and Automatic Information Gathering Technologies

Every time you use the Services (e.g., access a Service webpage, navigate to a specific location within the Service mobile app), we collect non-Personal Information (discussed above in Section 2) regarding that use.  For example, to improve our Services, we collect how, when, and which parts of the Services or its features you use, which social media platforms you connect to the Services, and when, how, and what you post to the social media platforms through the Service app.  Also, we may use your device’s unique identifier (UDID), media access control address (MAC Address), or other unique identifiers to assist us in collecting and analyzing this data.

To assist us in collecting and storing this non-Personal Information, we may employ a variety of technologies, including “Cookies,” local browser storage, and “Web Beacons.”  A “Cookie” is a small amount of data a website operator, or a third party whose content is embedded in that website, may store in your web browser and that the website operator or, as applicable, the third party, can access when you visit the website.  A Cookie may also refer to web-browser-based storage provided by Adobe’s Flash plugin (a “Flash Cookie”).  The Service’s Cookies may contain user preferences, unique identifiers, and other non-Personal Information. A “Web Beacon” is a small, usually-transparent image placed on a web page that allows the operator of that image, which may be the operator of the website you visit or a third party, to read or write a Cookie.

Your operating system and web browser may allow you to erase information stored in Cookies, Flash Cookies, and local browser storage. But if you do so, you may be forced to login to the Services again and you may lose some preferences or settings.  You may also be able to set your browser to refuse all website storage or to indicate when it is permitted, but some features of our Services may not function properly without it. 

More information about managing Cookies is available here. Cookie management tools provided by your browser may not affect Flash Cookies. More information about managing Flash Cookies is available here. To learn how to manage privacy and storage settings for your local browser storage, please refer to the end user documentation for your browser.

6.     Transparency and Choice

You may request access to your Personal Information by sending an email to support@creer.us]. We will try to locate and provide you with your Personal Information and give you the opportunity to correct this data, if it is inaccurate, or to delete it, at your request.  But, in either case, we may need to retain it for legal reasons or for legitimate business purposes. You may also remove any content that you post to the Services using the deletion or removal options within the Service, if available.  However, we (and you) are not able to control information that you have already shared with other users or made available to third parties through the Services.   

If you need further assistance with removing any content you posted through the Services, you can email us at support@creer.us. Removal of your posted content may not ensure complete or comprehensive removal from our computer systems.

We ask individual users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical (for instance, requests concerning information residing on backups), or relate to information that is not associated with your Personal Information.  In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

Please be aware that if you request us to delete your Personal Information, you may not be able to continue to use the Services.  Also, even if you request that we delete your Personal Information, we may need to retain certain information for a limited period of time to satisfy our legal, audit and/or dispute resolution requirements.

We may use third-party service providers that collect information for interest-based advertising purposes.  To learn more about these third parties and the choices they offer users, please visit the Network Advertising Initiative’s choices page or the Digital Advertising Alliance’s choices page.  If you are reading this Privacy Policy from a mobile device, you can learn more about the DAA's mobile choices program here.

We support the development and implementation of a standard "do not track" browser feature that provides customers with control over the collection and use of information about their web-browsing activities. Once a standardized "do not track" feature is released, we intend to adhere to the browser settings accordingly.

You can opt out of receiving marketing e-mails from us by clicking on the “unsubscribe” link in the e-mails.  Please note that it may take up to ten (10) business days for your opt-out request to be processed.  Also, even if you opt out of marketing e-mails, we may continue to send you certain account-related e-mails, such as notices about your account and confirmations of transactions you have requested.

7.     Children

The Services are not intended for users under 13 years of age.  We do not knowingly collect Personal Information from users under 13 years of age.  We do not authorize users under 13 years of age to use the Services. 

8.     Information Security

We utilize reasonable information security measures to safeguard your Personal Information.  For example, we utilize Secure Socket Layer (SSL), Transport Layer Security (TLS), or similar encryption technology when sensitive data is transmitted over the Internet, and use firewalls to help prevent external access into our network.  However, no data transmission over the Internet and no method of data storage can be guaranteed to be 100% secure.  Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its security.

9.     Your California Privacy Rights

A California resident who has provided Personal Information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California Customer”) is entitled to request information about whether the business has disclosed Personal Information to any third parties for the third parties’ direct marketing purposes.  In general, if the business has made such a disclosure of Personal Information, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom Personal Information was disclosed in the preceding calendar year, as well as a list of the categories of Personal Information that were disclosed.

However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public (in its privacy policy) a policy of not disclosing a customer’s Personal Information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, as long as the business maintains and discloses this policy.  Rather, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of Personal Information to third parties for direct marketing purposes and providing a cost free means to exercise that right.  To prevent disclosure of your Personal Information for use in direct marketing by a third party for its own purposes, do not opt in to or authorize such use when you provide Personal Information through the Services.  Please note that whenever you allow your Personal Information to be shared with a third party to communicate with you, your information will be subject to that third party’s privacy policy.  If you later decide that you do not want that third party to use your information, you will need to contact the third party directly.  You should always review the privacy policy of any party that collects your information to determine how that entity will handle your information.

California Customers may request further information about our compliance with California’s privacy law by e-mailing support@creer.us. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this e-mail address.

10.  Third Party Websites. 

Please note that the Services may link or integrate with third-party sites, services or apps.   We are not responsible for the privacy or security policies or practices or the content of such third parties.  Accordingly, we encourage you to review the privacy and security policies and terms of service of those third parties so that you understand how those websites collect, use, share and protect your information.

11.  Changes to this Policy

We may modify or update this Privacy Policy periodically with or without prior notice by posting the updated policy on this page. You can always check the “Last Updated” date at the top of this document to see when the Privacy Policy was last changed.  If we make any material changes to this Privacy Policy, we will notify you by reasonable means, which may be by e-mail or posting a notice of the changes on our website or through the Service’s mobile app prior to the changes becoming effective.  We encourage you to check this Privacy Policy from time to time.  IF YOU DO NOT AGREE TO CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING THE SERVICES AFTER THE EFFECTIVE DATE OF SUCH CHANGES (WHICH IS THE “LAST UPDATED” DATE OF THIS PRIVACY POLICY).

12.  Questions

To ask questions about our Privacy Policy or to lodge a complaint, contact us at: 

                                    Vireo Labs, LLC

                                    500 Carteret Street

                                    Beaufort SC 29902

                                    Email: support@creer.us