Please take a look at the privacy pledge for a summary of how Mambo pledges to protect your data.
Last updated May 25, 2018
Thank you for choosing to be part of our community at Mambo LLC (“company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at email@example.com.
TABLE OF CONTENTS
- 1. WHAT INFORMATION DO WE COLLECT?
- 2. HOW DO WE USE YOUR INFORMATION?
- 3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
- 5. DO WE USE GOOGLE MAPS?
- 6. WHAT IS OUR STANCE ON THIRDPARTY WEBSITES?
- 7. HOW LONG DO WE KEEP YOUR INFORMATION?
- 8. HOW DO WE KEEP YOUR INFORMATION SAFE?
- 9. DO WE COLLECT INFORMATION FROM MINORS?
- 10. WHAT ARE YOUR PRIVACY RIGHTS?
- 11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- 12. DO WE MAKE UPDATES TO THIS POLICY?
- 13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
1. WHAT INFORMATION DO WE COLLECT? Personal information you disclose to us
In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, and payment information.
We collect personal information that you voluntarily provide to us when registering at the Sites or Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites or Apps (such as posting messages in our online forums or entering competitions, contests or giveaways) or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Sites or Apps, the choices you make and the products and features you use. The personal information we collect can include the following:
Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.
Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information collected through our Apps
In Short: We may collect information regarding your geolocation, mobile device, push notifications, when you use our apps.
If you use our Apps, we may also collect the following information:
Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s calendar, reminders, contacts, social media accounts, sms messages, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to optout from receiving these types of communications, you may turn them off in your device’s settings.
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners, and other outside sources.
We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources
include: social media profile information; marketing leads and search results and links, including paid listings (such as sponsored links).
2. 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, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Sites or Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
To facilitate account creation and logon process with your Consent. If you choose to link your account with us to a third party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below headed “HOW DO WE HANDLE YOUR SOCIAL LOGINS” for further information
To send administrative information to you for Business Purposes. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
Fulfill and manage your orders for Contractual reasons. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Sites or Apps.
Request Feedback for our Business Purposes. We may use your information to request feedback and to contact you about your use of our Sites or Apps.
To protect our Sites for Legal Reasons. We may use your information as part of our efforts to keep our Sites or Apps safe and secure (for example, for fraud monitoring and prevention).
To enable user-to-user communications with your Consent. We may use your information in order to enable user-to-user communications with each user’s consent.
To enforce our terms, conditions and policies for Legal Reasons.
To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other
legal request, we may need to inspect the data we hold to determine how to respond.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.
We only share and disclose your information in the following situations:
Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental 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 and Legal Rights. 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.
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: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites or Apps, which will enable them to collect data about how you interact with the Sites or Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. 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.
Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
With your Consent. We may disclose your personal information for any other purpose with your consent.
5. DO WE USE GOOGLE MAPS?
In Short: Yes, we use Google Maps for the purpose of providing better service.
By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service. By using our implementation of the Google Maps APIs, you agree to allow us to gain access to information about you including personally identifiable information (such as usernames) and nonpersonally identifiable information (such as location). We will be collecting the following information:
For a full list of what we use information for, please see the previous section titled “HOW DO WE USE YOUR INFORMATION?” and “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” You agree to allow us to obtain or cache your location. You may revoke your consent at anytime.
The Maps APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Union, please take a look at our EU User Consent Policy.
6. WHAT IS OUR STANCE ON THIRDPARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you share with thirdparty providers who advertise, but are not affiliated with, our websites.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
8. 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. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites or Apps is at your own risk. You should only access the services within a secure environment.
SSL has been implemented on Mambo’s websites. While this encrypts all communication between Mambo and you, it will not prevent data theft if your computing device is compromised. You agree not to hold Mambo accountable in the instance of this unfortunate event.
PayPal is a leading payment and credit card processing service. PayPal’s Terms and Conditions are incorporated into this Agreement by reference and can be found here.
9. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites or Apps, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites or Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at firstname.lastname@example.org.
FERPA Statement (Family Educational Rights and Privacy Act).
The Family Educational Rights and Privacy Act (FERPA) is a Federal law that protects the privacy of student education records. The law applies to all schools that receive funds under an applicable program of the U.S. Department of Education.
The U.S. Department of Education released changes to the Family Educational Rights and Privacy Act (FERPA) on and effective December 9, 2008, to provide a more detailed map as educators and administrators navigate through emergency decisions and day-to-day management. The following summary of changes reflects the revisions, which will in some way affect the proceedings of campuses in contract with Mambo, LLC.
Third Party Release Data
The Department of Education has ruled that education records and personally identifiable information may be released—without consent—to third-party vendors, volunteers, and non-employees under the following proviso:
Contractors, volunteers, and any non-employees that have access to student records or identifying information must be included in the institution’s Annual Notification of FERPA as “school officials with legitimate educational interests.”
Third parties performing institutional services must be under “direct control” of the institution. Implications for Mambo users: The third-party release ruling came as a relief to most campuses, particularly those who have found a need to outsource institutional tasks to third-party vendors. The term “direct control” essentially implies that an institution must have and maintain ownership of all data released. In other words, an institution may not release data to any organization that intends to release or use that data for reasons outside the needs and requests of the university.
Third-party vendors are also held responsible for the data released to them.
Universities and colleges should not release data to vendors who have or had policies of releasing confidential data.
Mambo complies with the FERPA ruling, as a “school official with legitimate educational interests,” and can and ought to be listed as such in an institution’s Annual Notification of FERPA.
Mambo remains a responsible advocate for each of its campuses and does not and will not practice the release of data to any extent. Data released to Mambo is the property of the institution and under the direct control of that institution.
The Department of Education has ruled that student identification numbers (IDs) can now be included in directory information, given that they are not the sole identifier needed to access student education records. If used in combination with other identifying factors, student IDs can be used to validate the identity of an individual who is requesting personal records. Universities and colleges, however, must honor any student’s request to opt out of releasing directory information.
Implications for Mambo users
In the past, FERPA has ruled that student IDs could not be used as directory information for fear that the ID alone would provide access to confidential student education records. The new ruling clearly overturns this. The FERPA reasoning behind the change is largely in part to increased security measures on most campuses, where more than one identifying item is necessary to gain access to education records. If a student ID is the sole piece of information needed to access these records, student IDs may not be used as directory information, nor released publicly without student consent. However, Mambo qualifies as a “school official” under the FERPA terms and as such institutions may release data—both directory and confidential—to Mambo without fear of negligent practice.
Personally Identifiable Information
Under the previous policy, personally identifiable information was described as any information that was “easily traceable” to the student’s identity. However, FERPA now provides standards for defining personally identifiable information, such as indirect identifiers like mother’s maiden name, place of birth, date of birth, etc.
Implications for Mambo users
Because Mambo complies with the third-party release rules stipulated under FERPA, personally identifiable information may be released to Mambo. The items above predominantly affect communications inside a university and the extent to which personally identifiable information can be released publicly. The Department of Education has written a detailed description of their reasoning behind these changes in the FERPA final rule.
10. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/dataprotection/bodies/authorities/index_en.htm
If you would at any time like to review or change the information in your account or terminate your account, you can:
■ Contact us using the contact information provided.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites or Apps. To optout of interest-based advertising by advertisers on our Sites or Apps visit http://www.aboutads.info/choices/ .
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise optout, you may:
■ Access your account settings and update preferences.
11. 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 direct 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.
If you are under 18 years of age, reside in California, and have a registered account with the Sites or Apps, you have the right to request removal of unwanted data that you publicly post on the Sites or Apps. 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 Sites or Apps, but please be aware that the data may not be completely or comprehensively removed from our systems.
12. DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may email us at email@example.com or by post to:
3419 Westminster, PMB 288
Dallas, Texas 75205 United States
If you have any further questions or comments about us or our policies, email us at firstname.lastname@example.org or by post to:
3419 Westminster, PMB 288
Dallas, Texas 75205 United
States Phone: 469-573-3455
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here. We will respond to your request within 30 days.
Last Updated: 6/1/2018