23/03/2023

YourCampus Privacy Policy

YourCampus B.V. (“YourCampus”, “We”, “Our”, “Us”) provides an integrated platform for employee benefits-as-a-service through a mobile application (hereinafter the “Mobile App”), as well as a website (hereinafter: “Website”) containing relevant information to the services We provide (hereinafter collectively referred to as the “Service(s)”). The Mobile App enables You, the individual (“User(s)”, “You”, “Your”), to make use of experiences and offerings from third party providers (“Partner(s)”) and/or a monthly and/or a one-off budget (“Budget”) as offered to You by Your Employer (“Employer(s)”, “Customer(s)”).

This privacy policy (hereinafter “Privacy Policy”) describes and is intended to help Our Customers, Users, Partners and Our Website visitors understand the principles related to privacy that YourCampus holds dear to. This Privacy Policy describes how We collect information (including Personal Data as referred to in the General Data Protection Regulation), how We use that information, how We share that information and other relevant information regarding privacy, such as Your possibilities to access and update this information or exercise Your other rights with regard to the General Data Protection Regulation (“GDPR”). Use of Personal Data collected through the Services shall be limited to the purposes of providing the Services for which the User or Customer has engaged YourCampus, as described in this Privacy Policy, and otherwise with Your consent.

This Privacy Policy does not apply to any applications, services, products or software provided by Partners through the Services, those are governed by their own respective privacy policies.
Before using the Service or submitting any information to Us, please review this Privacy Policy carefully and contact Us if You have any questions. We have written a comprehensible summary (in italic) per clause for people of ages sixteen or seventeen who want to use Our Services.

We are committed to the protection of Your privacy while You use Our Services. By continuing to use Our Services, You acknowledge that You have had the chance to review and consider this Privacy Policy, and You acknowledge that You agree to it. This means that You also consent to the use of Your information and the method of disclosure as described in this Privacy Policy.

YourCampus provides software for employee benefits (extra’s that your Employer wants to provide to you) through a Mobile App and Our Website. We want to help You understand how We collect and use Your Personal Data when You use Our Mobile App or Website. We will only use Your Personal Data such that you can access and use our Mobile App and Our Website or to buy or receive employee benefits. We have a strict privacy policy and will not share your Personal Data with others unless We need to in order for you to buy or receive employee benefits, or to help You use Our Services.

Article 1 – Privacy Principles

  1. We follow these principles in order to protect Your privacy:
  2. We do not collect any more Personal Data than is necessary to provide the Services;
  3. We only use Your Personal Data for the purposes We specify in this Privacy Policy, unless You agree otherwise;
  4. We do not process Personal Data of individuals under the age of 16;
  5. We do not keep Your Personal Data if it is no longer needed; and
  6. Other than as We specify in this Privacy Policy, We do not share Your Personal Data with third parties, except with Your explicit consent to do so.

We limit the amount of Personal Data We gather as much as possible. We only use Personal Data such that You can buy or receive employee benefits. We don’t allow minors younger than sixteen (16) to use Our Mobile App or Website. We will remove Personal Data immediately after We are done using it and We no longer need to save it (for example because the law forces Us to save certain data). We don’t share Your Personal Data with other people or companies unless We need to, for example to be able for You to buy or receive employee benefits or to allow Us to set up the Mobile App or Website.

Article 2 – Purpose and the Personal Data We Collect

When You interact with Us through the Services or through any other means, We may receive Personal Data as well as other information and data (“Other Information”), as explained in more detail below.

Information You Provide Us

  • We collect Your Personal Data when ​​You or Your Employer register to use the Mobile App, provide information when using the Services, update Your account information, add additional Services, purchasing offers in the Mobile App, submit information to verify Your identity, contact customer support, contact Us with questions or feedback, or otherwise communicate with Us. This Personal Data may vary depending on what You or Your Employer choose(s) to share with Us and the Services You use, and may include identification information, professional or employment-related information, benefits enrollment information, financial information, commercial information, and online activity information. In addition, We may use Your information to send You direct marketing communications regarding the benefits offered and updates to Our Mobile App, with the purpose of ensuring You can optimally use the Mobile App. Through Our Services You always have the ability to unsubscribe from these direct marketing communications.

Information Third Parties Provide Us

​​​We may collect and receive information about You, including Personal Data, from third parties, such as Your Employer, Your Employer’s service providers, Our Partners, and Our own service providers, including for identity verification, fraud protection, and providing, updating, maintaining, and protecting the Services.

​​​- Other Information

- ​We may also collect, generate, and/or receive Other Information from the Services as follows:

    - Services Metadata. When You interact with the Services, metadata is generated that provides additional context about the way Our Users utilize the Services.
    - Log Data. As with most websites and technology services delivered over the Internet, Our platform automatically collects information when Our Services are accessed and record it in log files. Such log files may include the Internet Protocol (IP) address, the address of the web page visited before using the Services, browser type and settings, the date and time Services were used, information about browser configuration and plugins, language preferences and cookie data.
    - Device Information. We collect information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether We collect some or all of this Other Information often depends on the type of device used and its settings.
    - Location Information. We may receive information from You, Your Employer or any other third-parties that helps Us approximate Your location. We may, for example, use a business address submitted by Your Employer, or an IP address received from Your browser or device to determine approximate location.Cookie Information. We use cookies and similar technologies to operate and administer Our Services, gather and analyze usage, and improve Your experience. We may also allow third party service providers to use cookies or similar technologies to collect information about Your browsing activities over time and across different websites following Your use of the Services. For example, We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies to help Us analyze how Users use the Website and enhance Your experience when You use the Service. For more information on how Google uses this data, go to https://www.google.com/policies/privacy/partners. Cookies can be stored on Your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after Your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize Your computer when You open Your browser and browse the internet again (persistent cookies). For more details on cookies please visit https://www.allaboutcookies.org.
    - Additional Information Provided to Us. We also may receive Other Information when submitted to Our Website or in other ways, such as if You apply for a job, request support, interact with Our social media accounts or otherwise communicate with Us.

In addition to the above purposes, We use Your Personal Data for compliance with applicable laws and protection of Our legitimate business interests and legal rights, including but not limited to, Our right to use Your Personal Data in connection with legal claims, compliance, legal research purposes (including disclosure of such information in connection with legal proceedings or litigation).

Your Personal Data can be categorized as follows:

Contact details

  • Information used to verify/register You as a person using Our Mobile App. Generally this information is supplied by Your Employer to Us. This includes:
    • First name;
    • Last name;
    • Business or private e-mail address;
    • Hire date.
  • We may, additionally, receive the following information, depending on the agreement between YourCampus and the Employer for providing You with Our Services:
    • Date of birth;
    • Gross salary.

Communication details

  • We record Your IP address and unique device ID (MAC Address) and may assign other electronic identifiers to properly provide the Services or for security purposes. This includes (depending on the type of device used):
    • Mobile carrier
    • Device ID
    • Mobile advertising ID
    • Operating system
    • Browser type
    • IP address
    • MAC address

Support details

  • In the event that You submit a support request, We may need to collect the relevant support data to fulfill Your support request. This support data may include contact or authentication information, personalization of chat sessions or other data We need to fulfill Your support request. For some services, We may record usage data to assist Us with Your request for support.

Payment details

  • In order to purchase any of the Services on the Mobile App, You will be asked to provide certain credit information, billing address information, and possibly additional specific information such that You may be properly charged for Your purchases.

User details

  • We may record statistical information about Your use of the Services for Our business operations and to protect Our legal interests, in particular to improve the User experience and identify performance problems or other failures in the Service. This includes:
    • Geolocation information such as approximate location derived from IP address;
    • Internet activity information such as login and logout activities;
    • Pages You visit before, while, and after, using Our Services;
    • Pages You visit, content You view, and links You click, while on Our Website;
    • Demographic information;
    • Your particular preferences;
    • Combined or aggregated information, consisting of (some) of Your Personal Data in order to better serve You and to enhance and update Our Mobile App for You and other Users’ use.

We collect information about You when You use the Mobile App or Website. This can include information like Your name, job information, and financial information. We may also collect information from other sources like Your Employer or Partners to help provide Services to You, such as allowing a Partner to make a benefit available on Our Mobile App. We may also collect information about how You use the Mobile App or Website, Your device and location. We use this information to improve Our Service and may also use it to send You marketing messages. You can unsubscribe from these messages at any time. We also use cookies, which are small files stored on Your device, to remember certain preferences.

Article 3 – Exchange and Transfer of Your Personal Data

We may provide Your Personal Data to other companies such as Partners and suppliers of YourCampus and to other organizations providing services pursuant to an agreement with Us, for example for Our Services, to enable You to exercise Your ability to accept offerings and/or experiences from Our Partners, to provide support, to provide technical assistance, to resolve problems or to comply with legal requirements.

In some cases We must send Your Personal Data to other companies, for example such that they can give You access to a benefit You chose on Our Mobile App or Website, and even more, in some cases those companies will use Your information to provide other services, for example to answer Your questions regarding a benefit You chose on Our Mobile App. We use the same Personal Data to help answer any questions You might have.

Article 4 – Contact Us

If You have any questions about Our Privacy Policy or information practices, please feel free to contact Us at ​​privacy@yourcamp.us or by mail addressed to:

YourCampus
Ijsbaanpad 2
1076 CV Amsterdam
The Netherlands

You can always contact Us with any questions at the above mentioned addresses, however, only send us relevant information to the question and don’t give too many personal details unless We ask You to.

Article 5 – Data Location

Depending on the Services You use, Your Personal Data may be stored on servers of Our sub-processors located in different data centers. All data, including Personal Data, of YourCampus is processed within the European Economic Area, more ​​​​specifically in Ireland or the Netherlands.

All the data we use and collect, so also information about You, is stored and/or used on computers that are in a country that has to follow the same rules as in the Netherlands regarding information about You. In almost all cases this means that the data is either in the Netherlands or in Ireland.

Article 6 – Data Retention

We retain Your Personal Data for the term of the contractual relationship You or Your Employer has with Us, and, to the extent permitted, after the end of that relationship for as long as necessary to carry out the purposes described in this Privacy Policy. Laws may require Us to retain certain Personal Data for a specified period of time. Payment transactions related to the Services You use, for example, are retained for seven years pursuant to applicable tax laws.

We keep Your Personal Data with Us for as long as You use our Mobile App or Website. After that We will remove the data, with the exception of data we need to keep for a longer period of time due to laws that we have to follow.

Article 7 – Your Rights

You have the right to ask Us for a copy of Your Personal Data, to correct it, to delete or limit its processing, or to ask Us to transfer (some of) Your Personal Data to other organizations. You also have the right to object to certain processing activities, and to the extent that We have requested Your consent to process Your Personal Data, You have the right to withdraw this consent at any time.

These rights may be limited in certain situations, such as when We can prove that We are legally obliged to process Your Personal Data. If You wish to exercise Your rights, please contact Us using the contact details provided in this Privacy Policy.

You have certain rights about the information that YourCampus company has about You. You can ask Us for a copy of the information, tell us if there is something that's wrong and ask Us to fix it, ask Us to delete Your information or limit how We use it. You also have the right to ask Us to give Your information to another organization, and You can say no to some things We want to do with Your information. If You want to use these rights You can contact Us using the information in Article 4.

​Article 8 – Sub-processors

We engage sub-processors to provide (parts of) the Service(s) and process Your Personal Data. These sub-processors are prohibited from using Personal Data for purposes other than those specified in this Privacy Policy, and We contractually guarantee that the sub-processors and their employees maintain confidentiality with respect to the Personal Data and comply with the necessary instructions and security measures under this Privacy Policy or any relevant Data Processing Agreement between Us and the sub-processor.

The following sub-processors are engaged:

We work with other companies to help provide the Mobile App and Website to You. We make sure that these other companies promise to keep Your information safe and private, and only use it for the reasons specified in this document. We also have agreements with these other companies that make sure they follow strict rules and keep your information safe.

​Article 9 – Security

To protect Personal Data from unauthorized access, use, modification and accidental loss or destruction, YourCampus has implemented technical and organizational measures to secure the processing of Your Personal Data. In the event of a security breach affecting Your Personal Data, You will be notified without unreasonable delay as soon as the breach is identified. “Security breach” means any breach of security measures described in this Privacy Policy that accidentally or unlawfully results in the accidental or unlawful destruction, loss, alteration or unauthorized disclosure of, or the unauthorized access to, Personal Data that has been transmitted, stored or otherwise processed by Us. These measures include, but are not limited to:

  • preventing unauthorized persons from accessing data processing systems (physical access control);
  • preventing unauthorized use of processing systems (logical access control);
  • ensuring that persons authorized to use a data processing system have access to Personal Data only to the extent they are authorized to do so in accordance with their access rights and that Personal Data cannot be read without authorization, copied, modified or deleted during processing or use and after storage (access control to data);
  • ensure that Personal Data cannot be read, copied, modified or deleted without authorization, modified or erased during electronic transmission, circulation or storage on storage media, and that for any transfer of Personal Data, the target entities for data transport can be identified and verified (data transfer control);
  • ensure that measures are implemented for subsequent verification of whether Personal Data has been input, modified or deleted (erased), and by whom (input control);
  • ensure that Personal Data is processed only in accordance with instructions (job control);
  • ensure that Personal Data is protected against accidental destruction or loss (availability control)
  • ensure that Personal Data collected for different purposes can be processed separately (separation control).

We want to make sure Your information is safe and secure. We use special systems and rules to keep it from being seen or used by people who aren't allowed to. In case something happens that risks Your information, We will tell You as soon as possible.

Article 10 – Applicants

YourCampus processes applicants' Personal Data that could potentially be relevant to going through an application process, including information about the applicant's educational background and employment history. These data are processed because YourCampus has a legitimate interest in being able to assess whether the applicant's qualities match the job description.

The Personal Data that YourCampus receives as part of an application procedure will be deleted no later than 4 weeks after the end of this procedure, unless the applicant requests this earlier or if YourCampus has obtained permission to keep the data longer. In case the application procedure leads to the conclusion of an employment contract, the Personal Data will be kept for as long as necessary. For information on the processing of internal YourCampus employee personal data, please refer to the internal employee regulations of YourCampus.

We do not consider people under the age of 18 for any positions with Us.

Article 11 – Changes

We reserve the right to modify this Privacy Policy. Changes to this Privacy Policy are effective upon posting on Our Website and/or in Our Mobile App, and We will update the “Effective Date” at the top of this Privacy Policy. Also We will present any updated Privacy Policy to Our Users if and when it changes. Your continued use of the Services will be considered acknowledgement of the modified Privacy Policy.

If we make any changes to this policy We will let you know, either through the Mobile App or the Website. You can always see at the top of the policy when it was last changed. If you keep using the Mobile App or the Website we will assume you agree with it.