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Privacy Policy

Camp Walden Privacy Policy

Effective Date: June 15, 2023

Last Updated on: June 15, 2023

Camp Walden (hereinafter referred to as “Walden”) takes the protection of your personal data very seriously and adheres to the relevant statutory provisions and, in particular, the data protection laws in the various jurisdictions in which it does business, including – as far as applicable – the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), Virginia’s Consumer Data Protection Act (CDPA), the Colorado Privacy Act (CPA), the Connecticut Privacy Act (CTDPA) and the Utah Consumer Privacy Act (UCPA), (jointly, the Data Protection Laws).

To be in compliance with the relevant privacy laws, Walden adopts this Privacy Policy which applies solely to our clients and visitors (“user,” “you,” or “your”). This Privacy Policy explains our privacy practices related to your use of our website https://Campwalden.com/, and your rights regarding the collection, use and disclosure of your personal information. Any terms defined in the privacy law of a given state shall have the same meaning when used in this privacy notice, unless otherwise defined herein.

The following website (“Walden Website,” “Site” or “Website”) is operated by Camp Walden and its Affiliated Parties (collectively, “we,” “us” or “our”): https://campwalden.com/

This Privacy Policy (“Policy”) explains how we collect, use and protect information that we learn about you (“user,” “you” or “your”), as a result of your interaction with us through any Site on which this Policy is posted, including any Site you may access using your mobile, electronic or any other device and the Services provided through the Site as defined below.

Camp Walden includes Camp Walden and its trustees, officers, directors, shareholders, members, employees, representatives and agents (current and past) and any affiliates, individually and collectively.

Affiliated Parties means Camp Walden and any related individuals, affiliates and subsidiaries, and any of their trustees, directors, officers, shareholders, employees, representatives, consultants, attorneys, independent contractors, agents, suppliers, distributors, licensees or licensors.

Service or Services means any of the Site or other products or services provided or offered by us, including those described in this Policy, whether through a website owned, maintained or controlled by us, through a social network, a mobile application, on a cellular telephone or otherwise.

Walden respects your privacy and is committed to protecting the personal information that you share with us. Generally, you may browse through our Site without giving us any information about yourself. When we do need your personal information to provide the Services that you request or when you choose to provide us with your personal information, this policy describes how we collect and use your personal information.

Please read this Policy carefully before using or proceeding to access our Site. Your use of our Site indicates you have read and understood this Privacy Policy and indicates your agreement to its terms and our Terms of Use.

BY ACCESSING OUR SITE, YOU ARE ACCEPTING AND CONSENTING TO THE PRACTICES DESCRIBED IN THIS POLICY, AS UPDATED AND AMENDED FROM TIME TO TIME. IF, FOR ANY REASON, YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE STOP USING THE SITE IMMEDIATELY.

1. General Information

Walden is the controller regarding the processing of personal data. Please find more information about us on our about page.

If you have any questions regarding the processing of your personal data or our data protection policies in general, please contact us via email at walden@campwalden.com.

If you are a camper or an employee at Camp Walden, we use Campminder software which may collect personal information or data. Please refer to the Campminder Privacy Policy for more specific information.

2. Scope

This Privacy Policy will provide you with an overview of the types of personal data collected in connection with our website, for what purpose and on what legal basis. Personal data is all data relating to you personally, e.g. name, address, email address, user conduct. In addition, we will inform you of your rights towards us as the data controller.

3. Information We Collect

We may collect the personal information categories listed in the table below. We do not collect sensitive personal information.

In particular, through the Walden Website we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples	Collected	Business Purpose	Sold or Shared
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number or other similar identifiers.	NO unless you voluntarily provide it to us.	Collected by Campminder which in turn provides to Camp Walden for business use.	See Note 1 below.
B. Personal information categories listed by various states	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	NO unless you voluntarily provide it to us.	Collected by Campminder which in turn provides to Camp Walden for business use.	N/A
C. Protected classification characteristics under state or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO unless you voluntarily provide it to us.	Collected by Campminder which in turn provides to Camp Walden for business use.	N/A
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO	N/A	N/A
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO	N/A	N/A
F. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with our website, application or advertisement.	YES	To enable us to improve our website based on anonymous user data.	NO
G. Geolocation data	Physical location or movements.	NO	N/A	N/A
H. Sensory data	Audio, electronic, visual, thermal, olfactory or similar information.	NO	N/A	N/A
I. Professional or employment-related information	Current or past job history or performance evaluations.	NO	N/A	N/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information or student disciplinary records.	NO	N/A	N/A
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO	N/A	N/A

The Walden Website obtains the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products and/or services you purchase.
Indirectly from you. For example, from observing your actions on the Walden Website.

Note 1: We may share your personal information which you have shared with Campminder and we have obtained from Campminder with our uniform and luggage vendors unless you notify us at walden@campwalden.com that you wish to opt out. We may use the information our employees and our camp families share with Campminder and we obtain from Campminder to establish and maintain our relationship with our employees, our campers and the campers’ families.

4. Use of Personal Information

We may use, share, or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request more information or ask a question about Camp Walden, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To provide, support, personalize and develop the Walden Website, and/or our products and services.
To create, maintain, customize and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site, third-party sites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security and integrity of our Site, products and services, databases and other technology assets and business.
For testing, research, analysis and product development, including to develop and improve our Site, products and services.
To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about Walden Website is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you notice.

As a user, you also agree we may disclose information you provided about yourself to our employees, agents, contractors and sub-contractors, and our related and affiliated individuals and entities and their respective employees, agents, contractors and sub-contractors, in accordance with applicable law and for the limited purpose of administering the Site and Services we provide.

5. Data Processing on this Website

During the mere informational use of our Site, Walden will automatically collect and store information your browser transmits to us in the server log files. This data is technically necessary for us in order to show you our website and to guarantee its stability and security:

IP address
Date and time of the inquiry
Time zone difference to Greenwich Mean Time (GMT)
Content of the request (specific page(s))
Access status/http status code
The respectively transmitted data volume
Website from which the request comes
Browser, operating system and its graphic user interface
Language and version of the browser software

Walden will not attribute this data to specific persons and there will not be any merger of this data with other data sources. Once the data has been used for the above-mentioned purposes, we will delete it.

6. Cookies

We do not use cookies. A cookie may be left on your browser after visiting our Site but we do not use cookies for any information gathering or sharing of any kind. This would be default browser behavior and managed directly by the website user. We do not use “web beacons,” “web logs” and similar means allow our servers to automatically record information that your browser sends whenever you visit the Site. This information includes the time and date, your Internet Protocol address, your browser type and version, the Site and/or the Services that you use and when and for how long you use them. We use this information to monitor and analyze how users use the Site and our Services, to provide customer service and to maintain and improve our Services.

The information we collect and your use of our Site may be maintained in servers we control and maintain or in third party servers. The information you provide may be transferred or accessed by entities in many different countries. By submitting information, you agree to the transfer, storage and processing of your data in accord with this Policy.

7. Our Security Measures

The information you provide to us is stored on servers that are located in secured facilities with restricted access and protected by protocols and procedures designed to ensure reasonable security of such information. In addition, we restrict access to user data to those of our employees, independent contractors and agents who need to know this information in order to develop, operate and maintain the Site and evaluate use and purchase of Walden’s services and products. However, no data transmission over the Internet is completely secure nor can any be guaranteed to be totally secure, and, for this reason, we cannot ensure or warrant the security of any information you transmit to us. You can help protect your personal data and other information by using a combination of letters, numbers and characters in your password, changing your password often, using a secure web browser, and signing off and closing your web browser when you are finished with the use of the Site.

8. Google Analytics

Google Analytics collects information about how visitors use our site. We use the information to compile reports and to help us improve the site. Google collects information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages visited. You can click here to opt out of Google Analytics.

9. Google Maps

We use Google Maps on this website. This allows us to provide our location information in an easy and comfortable manner to you. If you use this functionality, Google may receive the data referred in Section 3 above. You can find more information about Google Maps here. We do not collect your location information.

10. Legal Basis to Process Personal Data

In some jurisdictions, like the European Union (EU), the European Economic Area (EEA), the United Kingdom (U.K.) and other jurisdictions where we do business, we only collect, use or share information about you based on the following legal grounds:

Consent. You may have consented to the use of your personal data, for example to send you electronic marketing communications or for the use of certain cookies. Consent may be withdrawn at any time. This will not affect the lawfulness of the processing before you withdrew your consent.
Contract. We need your personal data to provide you with our products and/or Services, to complete your requested transactions, and to respond to your inquiries.
Legal. We may process your personal data as necessary to protect your or another individual’s vital interests. Based upon your consent and/or our good faith belief it is reasonably necessary, we may also use your personal data as reasonably necessary to (i) comply with applicable laws, legal requirements, and company policies; (ii) to protect our assets and/or to investigate or defend against any claims of illegality or wrongdoing (including to obtain legal advice); (iii) to establish, exercise or defend legal rights); (iv) in response to a court order or judicial or other government subpoena or warrant; (v) to enforce this Privacy Policy (including any investigation of potential violations thereof); (vi) to detect, prevent, or otherwise address credit risk fraud prevention, security or technical issues associated with the Site and/or our products and services; and/or (vii) to protect our rights, property and/or the safety and/or the rights, property or safety of our employees, users of the Site and our products and/or services or those of others.
Legitimate Interest. We or a third party have a legitimate interest in using your personal data, such as preventing fraud or promoting our products and services. We only rely on this legal basis when such legitimate interests are not overridden by your interests or your fundamental rights and freedoms.
Your personal information is never shared with anyone other than us and our Affiliated Parties including employees, our independent contractors and agents, without your consent.
We may also share with third parties aggregated and anonymized information regarding the use of their services or websites such as the number of visitors to certain web pages or the number of users of certain services. Aggregated information does not include personal information that identifies individual users.
WE WILL NOT SHARE USER INFORMATION WITH THIRD PARTIES FOR THE PURPOSES OF THEIR DIRECT MARKETING TO YOU UNLESS YOU AFFIRMATIVELY AGREE TO SUCH DISCLOSURE.
Please do not share sensitive information with Us unless absolutely necessary and then do so in the most secure manner possible.

11. Tracking policy

We do not participate in tracking networks and do not intentionally or knowingly allow other parties to collect information about your on-line activities over time and across different websites, when you visit the Site or use any of our products and/or Services.

12. Sales/Sharing

We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary for the provision of their services. We share your personal information with our suppliers for marketing purposes and with The Main Idea summer camp for their fundraising purposes. For users described in Section 10 above, we do not share your personal information without your specific consent in compliance with applicable privacy law in those countries and as stated in Section 10.

To the extent that our practice constitutes a sale or sharing of your personal information, Global Privacy Control (GPC) is a setting you can enable in your web browser to communicate your privacy preference for not having certain information about your webpage visits collected across websites. For all the details, including how to turn on GPC, visit https://globalprivacycontrol.org/. Our website(s) that link to this Privacy Policy recognize and respond to GPC signals. You can also email us at the following email address: walden@campwalden.com

11. Children

The Camp Walden Website is intended for a general audience and is not directed at children under 13 years of age. We do not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act, or COPPA) in a manner not permitted by COPPA. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at walden@campwalden.com. We will remove the data to the extent required by applicable laws.

Consistent with our practice of not collecting data on anyone under 13 years old, we do not have actual knowledge that we share information on such minors with the parties with whom we share data.

12. Retention

We retain your personal data for the period necessary to fulfill the purposes for which it was collected and for a reasonable period thereafter to comply with our legal obligations, and contractual and business operational requirements.

At the expiry of the applicable data retention periods, we will take steps to have your personal information deleted, aggregated or made anonymous, unless further retention is required by applicable laws. We may be required to keep your information for as long as necessary (i) to comply with our legal and regulatory obligations, (ii) to make or defend legal claims, (iii) to protect against the fraudulent activity of others, (iv) to enforce our Privacy Policy, (v) to administer our Site and keep it safe and secure, and for internal operations (including, but not limited to, research, statistics, troubleshooting, data analysis, testing, survey and similar purposes); and (vi) to disclose as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to protect our operations or those of any of our Affiliated Parties; (c) to protect our rights, privacy, safety or property, or that of our Affiliated Parties, users or others; and/or (d) to allow us to pursue available remedies or limit the damages that we may sustain.

13. Walden in Social Media

In addition to our website, Walden is present on various social media. At present, you may find us on Facebook, Instagram, Twitter, LinkedIn, Vimeo and YouTube.

Please refer to the privacy policy of the respective operator to learn about the purpose and extent of data collection as well as the regulations on the use of your data by the respective platforms.

14. Your Rights

If you are an individual or consumer in one of the jurisdictions subject to the General Protection Data Regulation, then Walden is the Data Controller of your personal data. If so, then you have the following rights vis-à-vis us with regard to the personal data concerning you:

Right of transparent communication and information. You have the right to be informed about the controller’s (Walden) identity and contact details, the reasons or purposes for processing your personal data, the legal basis for doing so, recipients of that data (especially if those reside in third countries), and other relevant information necessary to ensure the fair and transparent processing of the data.
Right of access. You may ask us to provide you with a copy of the personal data we maintain about you, including a machine-readable copy of the personal data that you have directly provided to us, and request certain information about its processing.
Right to rectification. You may ask us to update and correct inaccuracies in your personal data. You also may ask us to complete information you believe is incomplete.
Right to erasure (‘right to be forgotten’). You may ask to have your personal data anonymized or deleted, under certain conditions.
Right to restriction of processing. You may request that Walden restrict the processing of your personal data, under certain conditions.
Right to data portability. You may request that Walden transfer the data we have collected to another organization, or directly to you, under certain conditions.
Right to object. You may object to Walden’s processing of your personal data, under certain conditions.
Right to not be subject to automated decision-making (to profiling). You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
Right to consent withdrawal. You may withdraw any consent you previously provided to us regarding the processing of your personal data at any time and free of charge. We will apply your preferences going forward. This will not affect the lawfulness of the processing before you withdrew your consent.

In order to assert these rights, please contact us at walden@campwalden.com.

Depending on the jurisdiction where you are located, you may also have the right to lodge a complaint with a supervisory authority on our processing of your personal data.

If you are a California, Colorado, Connecticut, Virginia or Utah resident:

Subject to certain limitations, you have the following rights with respect to the personal information we collect about you:

Right to know. You may ask us to give you information about our collection and use of your personal information. Specifically, you may request that we provide you one or more of the following:
- The categories of personal information we collect about you.
- The categories of sources from which we collect your personal information.
- Our business and commercial purposes for collecting, selling or sharing your personal information.
- The categories of third parties to whom we disclose, sell or share your personal information.
- The specific pieces of personal information we collect about you.
Right to delete. Subject to certain limitations, you may ask us to delete your personal information.
Right to correct. You may also ask us to correct inaccurate personal information that we have about you.
Right to opt out of targeted advertising or sale. You may ask us to stop using your personal information for targeted advertising. Please see the discussion on Sales/Sharing above.
Right against discrimination. We will not discriminate against you for exercising your rights.
Right to limit use of sensitive information. You may ask us to stop or otherwise limit the use of your sensitive information.

You may exercise your right to know, delete, or correct your personal information by emailing walden@campwalden.com. If you do not receive a confirmation of our receipt of your request within ten (10) days, we may not have received your request and you should re-submit it. Once we receive your request, we will attempt to verify your identity. We may ask you for additional information to help us verify your identity, including by asking you to confirm other personal information you have provided to us. We may deny your request for reasons permitted by law, including our inability to verify your identity. If we deny your request, we will tell you why we did so.

Subject to certain restrictions, you may have an agent exercise your rights for you. If you have an agent exercising your rights, that person must provide to us your written authorization allowing them to make such a request on your behalf. We reserve the right to deny the agent’s request if we are not reasonably able to confirm proper authorization and/or verify your identity as the requestor.

Other California Privacy Rights. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to walden@campwalden.com [or write us at: Camp Walden, P.O. Box 230, Denmark, Maine, 04022].

For users residing in Colorado, Connecticut, Utah and Virginia, in addition to the rights that are available to residents of California, if you are a resident of one of these states, you may also have the right to:

Opt out of the processing of your personal data for the purposes of targeted advertising and for profiling in furtherance of decisions, including, for residents of Connecticut, solely automated decisions, that produce legal or similarly significant effects; and
Appeal any decision or indecision related to the exercise of any right the consumer is granted under the applicable state law.

If you are a resident of Nevada, you also have the right to request that a company not sell your personal data for monetary consideration to certain other parties. This right applies even if your personal data is not currently being sold.

If you would like to exercise any of your rights under applicable law (including the right to appeal), please email walden@campwalden.com.

15. Changes to Our Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on our Site and update the notice’s effective date. Your continued use of our website following posting of the changes constitutes your acceptance of such changes.

16. Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at:

Phone: 207-452-2901

Website: www.campwalden.com

Email: walden@campwalden.com

Postal Address:

P.O. Box 230

Denmark, ME 04022

Attn: Kathy Jonas, Director

If you need to access this Privacy Policy in an alternative format due to having a disability, please contact walden@campwalden.com or 207-452-2901.

17. Security and Compliance

This Site has security measures in place to protect the loss, misuse and/or alteration of the information under our control, which includes the creation of unique user IDs and passwords, if applicable. However, we are not responsible if any third party evades our security procedures and gains access to your personal and/or sensitive information.

We comply with United States based privacy laws and regulations. We do not represent the Site is governed by, or operated in accordance with, the laws of other nations or jurisdictions, or that the Site or any portion of it is appropriate or available for use in any particular location. If you choose to access the Site, you do so at your own risk, and you are responsible for complying with all local laws, rules and regulations. By using the Site, visitors to it from outside the United States acknowledge and agree that our Site is subject to United States based laws and regulations and waive any claims against us that may arise under their own national laws.